Armstrong v. United States

MEMORANDUM AND ORDER

HOVLAND, Chief Judge.

Before the Court are cross-motions for summary judgment filed by the Plaintiffs and the Defendant. The Plaintiffs, Larry and Coleen Armstrong, initiated the above-entitled action to recover taxes they paid as a result of an allegedly erroneous assessment by the Internal Revenue Service (“IRS”). For the reasons set forth below, the Plaintiffs’ Motion for Summary Judgment is DENIED and the Defendant’s Motion for Summary Judgment is GRANTED.

I. BACKGROUND

This case is about two retirement accounts pledged as collateral for a personal loan. The dispute…