Frey

911 F.2d 738 Unpublished Disposition NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Mark T. FREY and Christine L. Frey, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. No. 89-55492. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 7, 1990. Decided Aug. 13, 1990. Before JAMES R. BROWNING and PREGERSON, Circuit Judges, and McKIBBEN, * District Judge. MEMORANDUM ** Appellants Mark and Christine Frey (the "Freys") appeal the district court's grant of summary judgment in favor of the United States. The district court held that the Internal Revenue Service ("IRS") had a legitimate tax lien on the Freys' property and that the IRS was not equitably estopped from asserting its lien rights. The court further found that the Freys could not establish priority over the tax lien under a theory of equitable subrogation. We affirm. FACTS Alvin and Patricia Feliciano owned real property in La Verne, California. The Felicianos encumbered the…