The Society of Apostolic Church Ministries Bishop, Elizabeth Gardner Corporation Sole and Her Succes

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS JUL 24 2025

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

THE SOCIETY OF APOSTOLIC No. 24-1765 CHURCH MINISTRIES BISHOP, D.C. No. ELIZABETH GARDNER 3:21-cv-08277-DJH

CORPORATION SOLE AND HER

SUCCESSORS,

MEMORANDUM*

Plaintiff - Appellant,

v.

UNITED STATES OF AMERICA,

Defendant - Appellee.

Appeal from the United States District Court for the District of Arizona Diane J. Humetewa, District Judge, Presiding

Argued and Submitted May 12, 2025 Phoenix, Arizona

Before: RAWLINSON, BUMATAY, and SANCHEZ, Circuit Judges. Dissent by Judge BUMATAY.

Plaintiff Society of Apostolic Church Ministries Bishop (“the Society”)

brought this suit against Defendant United States challenging the Internal Revenue

Service’s (“IRS”) tax lien on the Society’s Apache Knolls property and levy on the

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Society’s bank account to recover $826,381.05 in unpaid taxes owed by…