States v. Comparato, 850 F.Supp. 153, 159 (E.D.N.Y.1993), quoting United States v. Rodgers, 461 U.S. 677, 683, 103 S.Ct. 2132, 2137, 76 L.Ed.2d 236 (1983) (“once it has been determined that state law has created property interests sufficient for federal tax lien[s] to attach, state law ‘is inoperative to prevent the attachment’ of such liens”). The Second Circuit noted that “federal law controlled whether [the taxpayers’] interests were exempt from levy by the United States.” Id., 22 F.3d at 458, citing United States v. Rodgers, 461 U.S. 677, 683, 103 S.Ct. 2132, 2137, 76 L.Ed.2d 236 (1983). Because the Second Circuit holding in Comparato governs this case, Mrs. Adler’s renunciation is invalid as against the federal tax lien. But see, Mapes v. United States, 15 F.3d 138 (9th Cir.1994) (<HOLDING>). Consequently, any settlement proceeds to
holding that plaintiffs may have a property interest in real property holding that a renunciation pursuant to arizonas probate code does determine whether a person has any interest in property for federal tax purposes holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit holding that pursuant to maryland law the government maintains an everpresent interest in property owners land for tax purposes holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety