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VARDANEGA v. I.R.S.

No. 97-17301.

170 F.3d 1184 (1999)

Robert VARDANEGA, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 19, 1999.

Attorney(s) appearing for the Case

Paul H. Greisen, Greisen Law Corporation, Fair Oaks, California, for plaintiff-appellant.

William S. Estabrook, Murray S. Horwitz, Charles F. Marshall, Tax Division, United States Department of Justice, Washington, DC, for defendant-appellee.

Before: WOOD, THOMPSON, and THOMAS, Circuit Judges.

THOMAS, Circuit Judge:

Robert Vardanega appeals a decision of the U.S. District Court for the Eastern District of California. The district court in this case granted summary judgment in favor of the Internal Revenue Service ("IRS") in Vardanega's action to quiet title in real property. Vardanega argued below that 26 U.S.C. § 7425 permits the IRS to redeem only the exact property interest on which it has a tax lien. The district court disagreed and held that the...

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