United States v. Comer

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION ON PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT (Dkt. 56) AND DEFENDANT COMERS AND TRUST’S CROSS-MOTION FOR PARTIAL SUMMARY JUDGMENT (Dkt. 60)

BINDER, United States Magistrate Judge.

I.RECOMMENDATION

IT IS RECOMMENDED that plaintiffs and defendants’ motions both be GRANTED IN PART and DENIED IN PART as follows:

1. that as to the validity of notices, demands, and assessments, plaintiff United States’ motion be GRANTED;

2. that as to the enforceability of pre-bankruptcy petition tax liens for the years 1976, 1977, and 1985, both plaintiffs and defendants’…