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CODY v. U.S.

No. 1:04CV171.

348 F.Supp.2d 682 (2004)

Richard F. CODY, et al., Plaintiffs, v. UNITED STATES of America, Defendant/Third Party Plaintiff, v. Jerome P. Friedlander II, et al., Third Party Defendants.

United States District Court, E.D. Virginia, Alexandria Division.

December 13, 2004.

Attorney(s) appearing for the Case

Roger J. McClure, Alexandria, VA, for Plaintiffs.

MEMORANDUM OPINION

ELLIS, District Judge.

This suit concerns the validity of a federal tax lien. The central question presented is whether plaintiffs, who claim to own the liened townhouse property, are merely the nominee owners on behalf of the third-party defendant taxpayers, who live in the townhouse, are relatives of plaintiffs, and whose tax liability is the basis for the lien.

Plaintiffs commenced this declaratory judgment action against...

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