United States v. Judith Barnes

One day in June 2000, Judith Barnes received a call taxpayers dread. On the other end of the line was a man from the local Internal Revenue Service office, and he told her that she owed nearly $600,000 in taxes. After Barnes tried without success to challenge her liability for the tax assessment, the United States brought suit in 2008 to reduce the assessment to judgment. The Government moved for summary judgment, and the district court granted the motion and permitted the Government to enforce tax liens on two of Barnes’s properties to satisfy the outstanding tax liability. Barnes now…