The plaintiff bought a property at a non-judicial sale. The IRS had an I.R.C. Sec. 6321 lien against the property that had been filed more than 30 days before the sale. The IRS was not given notice of the sale at least 25 days before the sale. The IRS lien had been filed with the county. The plaintiff claimed that the lien was not valid, but the court determined otherwise. The IRS, the court held, did not get effective notice of the sale of the property. Thus, the IRS could foreclose the lien and had priority position against other creditors as to the proceeds of sale. Mendoza v. Cisneros, et al., No. 14-cv-3324-WJM-KMT, 2015 U.S. Dist. LEXIS 141416 (D. Colo. Oct. 14, 2015).