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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA Plaintiff, v. TIMOTHY J. STEWART, et al. Defendants.

) ) ) ) ) ) ) ) )

Civil Action No. 10-0400

MEMORANDUM Gary L. Lancaster, Chief Judge. This is a tax collection case. January 9, 2012

Plaintiff, the United

States of America ("United States"), seeks a judgment based on assessments for federal income and employment taxes against

defendants, Timothy J. Stewart, Debra L. Stewart, and Timothy J. Stewart, doing business as Stewart Sheet Metal. The United

States also seeks foreclosure of federal tax liens arising from tax assessments, and judicial sale of Timothy J. Stewart's

property to pay his tax liabilities. The judgment, United States has filed a motion not for summary the

arguing

that

defendants

have

rebutted

government's prima facie case of tax liability established by certified copies of tax assessments. [Doc. No. 38]. Defendants

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA Plaintiff, v. TIMOTHY J. STEWART, et al. Defendants.

) ) ) ) ) ) ) ) ) ORDER

Civil Action No. 10-0400

AND

NOW,

this

9th

day

of

January,

2012,

having

considered the United States' motion for summary judgment, and any opposition thereto, IT IS HEREBY ORDERED that the United States' motion for summary judgment [Doc. No. 38] is GRANTED; IT IS FURTHER ORDERED that judgment is entered in

favor of the United States, and against Timothy J. Stewart and Debra L. Stewart, in the amount of $82,435.20 plus interest

accrued after July 18, 2011; and that judgment is entered in favor of the United States, and against Timothy J. Stewart, doing business as Stewart Sheet Metal, in the amount of

$23,096.30 plus interest accrued after July 18, 2011; IT IS FURTHER ORDERED that the United States has valid and subsisting federal tax liens on all property and rights to property of Timothy J. Stewart and Debra L. Stewart, including



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