Harless v. United States

MEMORANDUM OPINION AND ORDER

VOLLMER, District Judge.

This matter comes before the court on cross-motions for summary judgment by petitioner Maurine Harless, as administra-trix of the estate of Larry J. Harless, and respondent United States as to whether a divorce judgment recorded in 1992 takes priority over a federal tax lien filed in 1996. After carefully reviewing the law and considering the submissions of the parties, 1 the court concludes that Ms. Harless, acting in her individual capacity, perfected her lien under the divorce judgment before the government filed notice of its federal tax…