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United States v. Brown & Co.

Citations

  • 10 Ct. Cust. 47
  • 1920 CCPA LEXIS 8

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that while whether a taxpayer conveyed a property to her daughters for adequate consideration under New York law was helpful, it was not dispositive of whether the daughters were federally-protected “purchasers” under § 6323(a)
  • vacating district court’s decision, in part, because purchasers did assume mortgage and did not just take property subject to the mortgage
  • noting, however, that this is a difficult question that, in similar contexts, has divided the courts for over a century
  • reviewing findings regarding the taxpayer's role in the company for clear error, but giving plenary review to conclusion that taxpayer's role made her responsible under 6672
  • finding absent a set aside of the pre-assessment conveyance under state law, the taxpayer did not have a legal interest in the property at the time the tax lien attached
  • “ ‘federal ... courts must look to state law’ to ascertain whether a taxpayer has a property interest in property subject to a federal tax lien.”

Source: CourtListener parenthetical corpus (CC0).

Judges: Barber, Martin, Montgomery, Smith, Vries, Yries

Read full opinion on CourtListener

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.