United States v. Davenport

MEMORANDUM OPINION

LEONARD, District Judge.

On December 19, 2000, plaintiff filed this action to reduce tax assessments for tax years 1990 through 1993 to judgment and to foreclose federal tax liens against real property 1 held by defendants Tommy D. and Linda Jean Davenport (“Davenports”). On October 18, 2005, the court entered partial summary judgment in favor of plaintiff, holding that the Internal Revenue Service (“IRS”) lien for tax year 1990 attached to the property at issue in this case on April 18, 1994. The court found genuine issues of material fact existed with respect to plaintiffs…