United States v. O'Brien
District Court, D. Maryland
1Opinion of the Court
Paul W. Grimm, United States District Judge
The United States has sued Timothy P. O'Brien in his individual capacity as Special Administrator of the insolvent Estate of Louis C. Pate (the "Estate"), and Diane V. Marshall, in her individual capacity as Representative of the Estate. Count I seeks to collect "Mr. Pate's unpaid federal income taxes, penalties, and interest assessed against Mr. Pate for the 2004 tax periods and ... the 2007-2009 tax periods" through a judgment against O'Brien or, alternatively, against Marshall. Am. Compl. 1-2 & ¶¶ 11-16, ECF No. 10.1
*521O'Brien has moved to dismiss…
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