This case arose from the actions of a title insurance company which issued a policy insuring title to a property without excepting an Internal Revenue Service lien despite its knowledge of the lien’s existence. The insurance company sought to recover the amount eventually paid to the IRS on behalf of its policyholder from the trustee who, lacking knowledge of the existence of the lien, conducted a foreclosure sale years earlier without notifying the IRS. The policyholder joined in the suit against the trustee. There is no requirement of the trustee is to notify the IRS under the terms of a federal statute.