Kiley, Fairchild and Kerner, Circuit Judges.
The United States sought to enforce a federal tax lien against a parcel of real estate owned by intervening defendant-appellant Bluhm. The District Court granted summary judgment for the United States from which Bluhm appeals.
On December 24, 1966, the United States filed suit to reduce various tax liens to judgment against defendants John A. Amos and Gertrude P. Amos. A default judgment was entered against John and Gertrude Amos in the amount of $210,101.13 and a separate judgment against John Amos, alone, for $9,575.25. The Amos' owned a parcel of real estate located at 831 Ashland, Wilmette, Illinois. Notices of federal tax liens were filed with the Recorder of Deeds as follows:
Taxable Date of Date Notice of
Year Assessment Tax Lien Filed
1950 May 23, 1958 September 3, 1958
1951 May 23, 1958 September 3, 1958
1952 May 23, 1958 September 3, 1958
1953 May 23, 1958 September 3, 1958
1954 February 3, 1961 April 10 and 24, 1961
1957 September 27, 1963 February 4, 1964
1958 September 27, 1963 February 4, 1964
On February 27, 1962, the Amos' not having paid the real estate taxes for 1960, the real estate was sold at a tax sale and a certificate of sale was issued to Bonded Municipal Corporation. No redemption having taken place within the provided time, Bonded sought the issuance of a tax deed in the Circuit Court of Cook County. In November, 1964, notice of the action in Circuit Court was given to the District Director of Internal Revenue, Chicago, Illinois, the United States District Attorney for the Northern District of Illinois and the Attorney General of the United States, Washington, D.C. The United States did not respond and on June 18, 1965, a tax ...