United States v. Wesselman

*65ORDER

The government sued Herman Wesselman under 26 U.S.C. § 7403 to reduce to money judgment unpaid assessments for tax, penalties, and interest; and to foreclose on tax liens. The district court granted summary judgment for the government, and Wesselman appeals. We affirm.

For years, Wesselman did not file tax returns for himself or his roofing business. The Internal Revenue Service caught up with him and in 1993 began an audit of Wesselman and his business. After Wesselman refused the IRS’s requests for documents needed to determine his tax liability, the IRS reconstructed his income,…