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involving a tax lien inasmuch as the provision recognizes that
the application to intervene may be denied).11
Consistent with the preceding discussion, we hold that the
portion of respondent’s notice which states that Mr. Murray may
intervene in this case only for the purpose of opposing
petitioner’s claim for relief is incorrect. Accordingly, we
shall grant petitioner’s motion to strike in that the restrictive
language in respondent’s notice, filed March 8, 2004, shall be
deemed stricken. Further, the Court will direct that Mr.
Murray’s notice of intervention be filed.
To reflect the foregoing,
An order will be issued
granting petitioner’s motion
to strike and directing that
the notice of intervention,
lodged April 1, 2004, be filed.
11Sec. 7424 provides in pertinent part:
If the United States is not a party to a civil
action or suit, the United States may intervene in such
action or suit to assert any lien arising under this
title on the property which is the subject of such
action or suit. * * * In any case in which the
application of the United States to intervene is
denied, the adjudication in such civil action or suit
shall have no effect upon such lien.
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