- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
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