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1995, WLLC’s assets were transferred to a Florida limited
partnership, West Lakeland Land Co., Limited Partnership (WLLC
Ltd.), in exchange for a 99-percent limited partnership interest in
WLLC Ltd. Fridovich Holdings, Inc. (owned by Debbie Fridovich,
petitioner’s sister, and Anthony Fridovich), held a 1-percent
general partnership interest in WLLC Ltd.
On March 19, 1996, the Internal Revenue Service filed Notices
of Federal Tax Lien against WWLC Ltd., naming the partnership as
nominee of the estate. On June 13, 1996, WLLC Ltd. brought suit
against the United States, see West Lakeland Land Co., Ltd.
Partnership v. United States, case No. 96-1157-CIV-T-21 (M.D.
Fla.), to quiet title with respect to the partnership property and
for release of liens.
On October 22, 1996, WLLC Ltd. filed for bankruptcy under
chapter 11. See In re West Lakeland Land Co., Ltd. Partnership,
case No. 96-14434-8CI (Bankr. M.D. Fla.), appeal docketed, No. 98-
1609-CIV-T25E (M.D. Fla. Aug. 3, 1998). On November 12, 1996, the
partnership filed an adversary complaint against the United States
in its bankruptcy case, challenging the validity of the
Government’s nominee liens. See West Lakeland Land Co., Ltd.
Partnership v. United States, 216 Bankr. 892 (Bankr. M.D. Fla.
1998), appeal docketed, No. 98-548-CIV-T23A (M.D. Fla. Mar. 16,
1998). On February 3, 1998, the bankruptcy court entered a
judgment and opinion, finding that the nominee liens were invalid
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