United States v. Glen Upton, Inc.

MEMORANDUM AND ORDER

JOHN W. OLIVER, District Judge.

The present cause is an action brought to foreclose a federal tax lien against a parcel of real property purchased by the defendant from the taxpayer. With regard to the government’s claim, which is separately considered pursuant to Rule, 42(b) of the Rules of Civil Procedure, the parties have agreed that no oral evidence need be presented and have submitted the case on a stipulated factual record. We have carefully reviewed the Stipulation and the briefs of the parties and make the following findings of fact and state the following…