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U.S. v. ALLAHYARI

No. 18-35956, No. 18-36076.

980 F.3d 684 (2020)

UNITED STATES of America, Plaintiff-Appellee, v. Komron M. ALLAHYARI, Defendant, and Shaun Allahyari, Defendant-Appellant. United States of America, Plaintiff-Appellant, v. Komron M. Allahyari; Shaun Allahyari, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Filed November 13, 2020.

Attorney(s) appearing for the Case

Avi J. Lipman (argued), Gregory J. Hollon , and Curtis C. Isacke , McNaul Ebel Nawrot & Helgren PLLC, Seattle, Washington, for Defendant-Appellant/Cross-Appellee.

Komron R. Allahyari, Mercer Island, Washington, pro se Defendant/Cross-Appellee.

Karen G. Gregory (argued) and Deborah K. Snyder , Attorneys; Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Tax Division, United States Department of Justice; for Plaintiff-Appellee/Cross-Appellant.

Before: Milan D. Smith, Jr. and N. Randy Smith, Circuit Judges, and John R. Tunheim, Chief District Judge.

OPINION

Shaun Allahyari ("Shaun") appeals the district court's determination that his alleged security interest in property owned by his son, Komron Allahyari ("Komron"), a tax delinquent, was not entitled to priority over later-recorded federal tax liens. He argues that the district court erred when it found...

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