United States v. Towne

MEMORANDUM OPINION AND ORDER

ST. EVE, District Judge.

Plaintiff United States of America (“United States” or the “Government”) sued Defendants Jane Harris and Peter Swan (collectively “Swan”) seeking to secure Thomas and Joen Townes’ (the “Townes” or “Taxpayers”) federal income tax liability by foreclosing federal tax liens pertaining to real property located in Lib-ertyville, Illinois. The Court held a bench trial on November 15, 2005. 1 For the reasons discussed below, the Taxpayers do not have any “property” or “rights to property” to the subject property to which the relevant federal tax…