Bowen v. United States Internal Revenue Service (In Re Bowen)

MEMORANDUM OPINION

JUDITH A. BOULDEN, Bankruptcy Judge.

PROCEDURAL BACKGROUND

A petition for relief under Chapter 11 of the Bankruptcy Code was filed by Mack J. and Dorothy Bowen (Bowens) on the 29th day of August, 1986. The United States Internal Revenue Service (I.R.S.) filed an amended proof of claim in the case in the amount of $78,225.59. 1 The Bowens filed this adversary proceeding to determine the extent of the I.R.S.’s lien on the Bowens’ property, to object to the claim of the I.R.S., and to request an injunction against the I.R.S.’s filing a “protective claim”. 2 The I.R.S. asserts…