United States v. Ronald C. Gibson, Dba Gibson Construction Company, State of Oregon

CYNTHIA HOLCOMB HALL, Circuit Judge:

I

Ronald C. Gibson owned and operated Gibson Construction Company as a sole proprietorship during tax years 1977 through 1981. During those years he failed to pay certain taxes. His total unpaid tax liability, including interest, amounted to $69,161.55. The government filed notices of federal tax liens on two pieces of property in which Gibson had an interest at the time. After unsuccessful attempts at collection, the government commenced this action pursuant to 26 U.S.C. § 7403 seeking foreclosure of these two pieces of property.

The parties consented to a…