Case: Ohio Law Does Not Recognize Nominee Property Ownership For Attachment of Federal Tax Liens (S.D. Ohio)

Federal tax liens did not attach to the property held by Taxpayer’s mother because Ohio law does not recognize the nominee theory of property ownership, the district court held, granting summary judgment for Taxpayer. Taxpayer, an individual with federal tax liabilities, resided in a property titled in his mother’s name. The government sought to enforce tax liens against the property, arguing that Taxpayer is the true equitable owner of the property and the mother held bare legal title as Taxpayer’s nominee. The court held that the government had valid tax liens against all of Taxpayer’s property. However, the court held ...