Crisp v. United States

MEMORANDUM OPINION AND ORDER RE: GOVERNMENT’S MOTION TO DISMISS

WANGER, District Judge.

I. INTRODUCTION

On December 4, 1996, Plaintiffs Gilbert Mark Crisp and Rhonda Crisp (“the Crisps”) filed a complaint against the government, alleging that the government has no valid lien claims against them based on income tax deficiencies. Now the government moves to dismiss the complaint for lack of subject matter jurisdiction; the Crisps oppose this motion.

II. BACKGROUND

The Crisps timely filed federal income tax returns for the calendar years 1988 and 1989. On April 6, 1995, the Internal Revenue Service…