Department of Revenue v. Shea

For almost twenty years, the Commonwealth’s Department of Revenue (DOR) has been trying to collect taxes owed by Gladys M. Shea (Gladys) and her now-deceased husband, Raymond E. Shea, Sr. (Raymond), for the four taxable years, 1980 through 1983.2 The collection effort has had four distinct phases. The first addressed the propriety of the DOR’s assessments. That phase was followed by a period of settlement negotiations. Shortly before negotiations ended, litigation ensued with respect to whether certain real estate could be seized and sold to satisfy the unpaid taxes. We concluded that phase…