United States v. Johnson

MEMORANDUM AND ORDER

VAN BEBBER, Chief Judge.

This matter is before the court on plaintiffs motion (Doc. 14) for summary judgment pursuant to Fed.R.Civ.P. 56. Defendants have responded and oppose the motion. For the reasons set forth below, plaintiffs motion is denied.

This is a foreclosure action in which the United States is engaging in the collection of a judgment for unpaid employment tax assessments it obtained against defendant Ray H. Johnson in another proceeding. The United States now seeks the foreclosure of Ray Johnson’s undivided one-half interest in real estate. The other co-tenant…