United States v. Brown & Co.

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).