U.S. v. HOLLAND

No. 18-1712.

953 F.3d 397 (2020)

UNITED STATES of America, Plaintiff-Appellant, v. Edward J. HOLLAND, Jr., Defendant, Edward Holland L.P., The Royal Bank of Scotland Group PLC; Frederick A. Patmon, Sr.; Peggy Young, as the personal representative of the Estate of Hallison H. Young, Defendants-Appellees.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: March 10, 2020.


Attorney(s) appearing for the Case

ARGUED: Geoffrey J. Klimas , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellant. Neal Nusholtz , NEAL NUSHOLTZ, P.L.L.C., Troy, Michigan, for Appellee Edward Holland L.P. Gregory J. Fleesler , MOSES & SINGER LLP, New York, New York, for Appellee The Royal Bank of Scotland. ON BRIEF: Geoffrey J. Klimas , Joan I. Oppenheimer , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellant. Neal Nusholtz , NEAL NUSHOLTZ, P.L.L.C., Troy, Michigan, for Appellee Edward Holland L.P. Gregory J. Fleesler , Matthew Handler , MOSES & SINGER LLP, New York, New York, for Appellee The Royal Bank of Scotland. Avery K. Williams , WILLIAMS ACOSTA, PLLC, Detroit, Michigan, for Appellee Estate of Hallison H. Young through its personal representative, Peggy Young.

Before: McKEAGUE, KETHLEDGE, and MURPHY, Circuit Judges.


OPINION

For decades the government has tried, on a rolling basis and with varying success, to collect millions of dollars of unpaid taxes from Edward Holland, Jr. Here, the government seeks to seize about $20 million of assets previously held by a partnership created by Holland, on the theory that the partnership...

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