IRS v. Blue Mountain Ministry, Inc.

The Pennsylvania Superior Court clarified the difference between a judgment and a lien — and sidestepped ruling on the defendants’ claim that the IRS is a for-profit Delaware corporation, which is merely a debt collector. After the IRS placed a lien on their property, the defendants argued in the Court of Common Pleas that the IRS is not part of the federal government or a legitimate governmental entity. They sought $1.8 million in damages. The Superior Court resolved the matter on a less scandalous basis. The Court found that the IRS had filed a notice of a federal tax lien, not a judgment. And the prothonotary applied the wrong label, which the trial court should have corrected as a clerical error or a mistake. Beyond that, the state courts do not have the authority to revoke or modify a federal lien. Thus, allegations aside, the state courts did not have jurisdiction over the substance of the matter.

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