Case: Government Entitled to Foreclose Tax Liens on Property (S.D. Ga.) (IRC §7403)

The government was entitled to foreclose its tax liens on the property and distribute sale proceeds according to the established priority order, the district court held, granting the government’s motion for summary judgment. Taxpayer, an individual, had acquired real property and failed to pay income and employment taxes and penalties for several years. The government recorded various tax liens against the property and sued to enforce them, naming as defendants other parties with recorded encumbrances on the property. The court held that the federal tax liens attached to the property when the assessments were made, and the government was entitled ...