Popky v. United States

MEMORANDUM

O’NEILL, District Judge.

I. INTRODUCTION

Plaintiffs Howard D. and Sheila A. Pop-ky seek to quiet title to proceeds from the sale of a property held in a tenancy by the entireties. Plaintiffs also seek a refund of the proceeds that the Internal Revenue Service collected by levy and applied to satisfy the trust fund tax liabilities of Sheila A. Popky in the amount of $43,324.43. Defendant United States seeks a judgment against Sheila Popky for the balance of the unpaid trust fund taxes. Now before me are the parties’ cross-motions for summary judgment. For the reasons set forth below, I…