McPherson v. United States

ORDER

DONALD W. MOLLOY, District Judge.

I. Introduction

Robert and Orma McPherson, Canadian citizens residing in Calgary, Alberta, have a vacation property on Flathead Lake in Poison, Montana, hereinafter called the “vacation property.” 1 The Government of Canada contends that Robert failed to pay taxes on income earned during years 1995— 1998. The United States Internal Revenue Service (“IRS”), acting on behalf of the Canadian government pursuant to Article XXVI A of the United States — Canada Income Tax Convention, issued a levy against Robert reflecting back taxes and penalties in the amount…