Brownfield Investment Corporation, N v. V. United States

28 F.3d 105 74 A.F.T.R.2d 94 -5452 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. BROWNFIELD INVESTMENT CORPORATION, N.V., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. No. 92-16621. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 9, 1994. Decided July 13, 1994. 1 Before: ALARCON and FERNANDEZ, Circuit Judges, and WILSON, District Judge. 1 MEMORANDUM 2 2 Brownfield Investment Corporation ("Brownfield") filed this quiet title action seeking the removal of an IRS tax lien filed February 22, 1988, encumbering real property owned by plaintiff. Brownfield alleged that the lien was improperly filed because the lien relied on the tax liabilities of Dushyant Patel. The IRS claimed that the lien was proper because Brownfield was the alter ego of Dushyant Patel. Following a court trial, the district court (Judge Patel) concluded that Brownfield was the alter ego of Dushyant Patel and that the lien was proper. Brownfield appeals this…