O'Bryant v. United States

ORDER

McDADE, District Judge.

On November 12, 1990, the IRS made an assessment of $9,438 against Plaintiffs, Raymond E. O’Bryant and Dorothy J. O’Bryant, [“Plaintiffs”], for federal income taxes due in 1989. 1 Because Plaintiffs have not paid their total 1989 income tax liability, Defendant, the United States of America, has filed a Federal Tax Lien which continues to encumber their real property, and title to that property cannot be quieted until the 1989 assessment is satisfied.

Before the Court are Cross-Motions for Summary Judgment on Count II of the United States’ Counterclaim. In Count II,…