Mayer-Dupree v. Internal Revenue Service
United States Court of Appeal for the Tenth Circuit
1993 U.S. App. LEXIS 24639 (1993)
Mayer-Dupree (plaintiff) bought a vehicle from a delinquent taxpayer in 1986 and received the certificate of title but never registered it with the state. Federal tax liens against the seller had accrued in 1985 and were noticed in 1988 and 1990. In 1991, the IRS (defendant) seized the vehicle to satisfy those liens; only after the seizure did Mayer-Dupree register the title. Mayer-Dupree filed a wrongful-levy action, and the district court granted summary judgment to the IRS.
Whether, to prevail as a purchaser over a federal tax lien, the buyer of the encumbered property must acquire a valid interest under state law against a subsequent purchaser without actual notice of that interest.