Case: Federal Tax Lien on Property Acquired by Quitclaim Deed Remained Valid After Transfer (E.D. Mo.) (IRC §7425)

The federal tax lien acquired by quitclaim deed remained valid and enforceable despite the original owners’ lack of current ownership interest, the district court held. Taxpayer, an individual, acquired real property by quitclaim deed. The IRS had previously recorded a tax lien against the property’s former owners. The property was later sold at a tax sale to a third party, who then transferred it to Taxpayer. Taxpayer filed a quiet-title action against the government, arguing the lien was invalid or unenforceable because the former owners no longer had an ownership interest. The court held that the federal tax lien attached ...