Carter v. Carter

MEMORANDUM OPINION

ELLIS, District Judge.

Introduction

In this case, a federal tax claim and a prior judgment lien compete for the same assets. The case has an involved history; it grows out of an apparently hotly contested divorce action. The government’s claim is based on federal income tax deficiencies assessed initially against the husband and wife, defendant William D. Carter and complainant Carole V. Carter. Defendant T- CAS America, Inc. (T-Cas) has a judgment lien on the same assets based on the husband’s unpaid debts to T-Cas. The assets involved are the proceeds from the sale of the…