The Fourth Circuit reversed. The Court held that the IRS was not required to list the full amount of interest in the Certificate. According to the Court:
Although establishing the amount of tax liability is a matter of evidence, the amount of interest accrued on such tax liability is a matter of law. United States v. Schroeder, 900 F.2d 1144,1150 n.5 (7th Cir. 1990). Therefore, the government provided sufficient evidence to prove that Sarubin owed the underlying tax debt sought, which debt has in turn accrued interest by operation of statute.The district court’s suggestion that the government failed to show a prima facie case by attaching the Certificates and citing to § 6601(a) was thus inaccurate.
Hence, the district court's decision was reversed.