Yuma Title & Trust, an Arizona Corporation v. Mary Jane Lane, and United States Internal Revenue Service

967 F.2d 597 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. YUMA TITLE & TRUST, an Arizona corporation, Plaintiff, v. Mary Jane LANE, Defendant-Appellant, and UNITED STATES INTERNAL REVENUE SERVICE, Defendant-Appellee. No. 91-15010. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 10, 1992. Decided June 16, 1992. Before JAMES R. BROWNING, PREGERSON and RYMER, Circuit Judges. 1 MEMORANDUM * 2 Mary Jane Lane appeals the district court's decision denying her motion for summary judgment and granting the government's cross-motion for summary judgment. Both parties were responding to an interpleader action initiated by Yuma Title & Trust ("Yuma Title") in Yuma County, Arizona Superior Court. In that action, Yuma Title requested a declaration of the priority of claims to proceeds from an escrow account. We affirm the district court's decision. 3 Mary Jane Lane loaned her son, C. Bradley Lane ("taxpayer"), $190,000 in 1978 for the purchase of…