United States v. Cohen

OPINION

RICHARD MILLS, District Judge.

The Complaint in this case was filed on December 2, 2008, but its origins date to the early 1980s.

The bench trial in this case took nine days, heard from twelve witnesses, and the record amounts to thousands of pages.

Judgment for the United States.

I. INTRODUCTION

This is an action for foreclosure of federal tax liens, wherein the Court has jurisdiction pursuant to 28 U.S.C. §§ 1340 and 1345 and 26 U.S.C. §§ 7401 and 7403. Venue is proper in this Court pursuant to 28 U.S.C. § 1396 because the real property which is the subject of this suit is located in…