United States v. Doyle

OPINION

COHILL, Senior District Judge.

Currently pending before this Court is the Motion for Summary Judgment filed by the United States of America (“United States” or “Government”) as against Defendants S. Byrne Doyle (“Mr.Doyle”), Barbara S. Doyle (“Mrs.Doyle”), Maureen Doyle, Brian Doyle, Kathleen Dorsch, Richard Dorsch and Bank of America. Hereinafter S. Byrne Doyle and Barbara S. Doyle will be referred to as the “Taxpayers.” Only the Defendant Taxpayers opposed the United States’s Motion for Summary Judgment. 1 In Counts I and II of the Second Amended Complaint, the United States alleges…