Rebecca Brown Brinskele

CourtUnited States Bankruptcy Court, N.D. California
DecidedApril 23, 2021
Docket18-30194
StatusUnknown

This text of Rebecca Brown Brinskele (Rebecca Brown Brinskele) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rebecca Brown Brinskele, (Cal. 2021).

Opinion

EDWARD J. EMMONS, CLERK 13 □□ \o. U.S. BANKRUPTCY COURT □□ NORTHERN DISTRICT OF CALIFORNIA □□ Sal □□ 1 . . . \ □□□ □□ Signed and Filed: April 23, 2021 □□□□□□ □□ 2 Mini hi 4 Vine 5 DENNIS MONTALI U.S. Bankruptcy Judge 6 7 UNITED STATES BANKRUPTCY COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 In re ) Bankruptcy Case 10 ) No. 18-30194-DM REBECCA BROWN BRINSKELE, ) 11 ) Chapter 11 12 Debtor. ) )} Date: March 26, 2021 13 ) Time: 10:30 AM 1 ) Via Tele/Videoconference <= 15 MEMORANDUM DECISION REGARDING IRS’S MOTION FOR SUMMARY JUDGMENT AND DEBTOR’ S CROSS-MOTION FOR SUMMARY JUDGMENT 16 AND OBJECTION TO IRS’S CLAIM 17 The Internal Revenue Service (“IRS” or “United States”) 18 and Edward A. Brinskele (“Spouse”) have been at war for more 19 \lthan two decades, with the IRS repeatedly winning these legal 20 llpattles. Rebecca Brown Brinskele (“Debtor”) has now assumed 21 llthe mantle from Spouse but the undisputed facts and governing 22 once again mandate a result in favor of the IRS as 23 lldiscussed below. 24 I. THE UNDERLYING PROOF OF CLAIM AND MOTIONS FOR SUMMARY 25 JUDGMENT 26 On December 21, 2001, the United States assessed over 27 |}$950,000 in trust-fund-recovery penalties against Spouse under 2g U.S.C. § 6672. The IRS filed a proof of claim that included -l1-

1 these trust fund penalties and a judgment relating to them. 2 See Claims 1-1, 1-2, 1-3, and 1-4. Debtor filed an objection 3 to the IRS’s claim on July 16, 2019. See Debtor’s Objection to 4 Claim No. 1 of the IRS (dkt. 53) (“Claim Objection”). 5 On November 30, 2020, the United States filed a motion for 6 summary judgment (the “Motion”) in opposition to the Claim 7 Objection (dkt. 98). It asserted that Debtor is precluded from 8 challenging taxes assessed against Spouse and that Debtor 9 cannot meet her burden of showing that the IRS’s claim has been 10 paid. Debtor opposed the Motion and filed a cross-motion for 11 summary judgment, asserting that tax transcripts reflect that 12 the IRS’s judgment lien had been removed, that the tax 13 assessments against Spouse violated due process and 14 constitutional law, and that she had standing to object to the 15 assessments against Spouse. For the reasons set forth below, 16 the court determines the IRS’s position is well-taken and that 17 Debtor’s position is inconsistent with existing judicial 18 rulings regarding the tax assessments against Spouse. 19 II. UNDISPUTED FACTS 20 On May 30, 2002, the United States recorded a Notice of 21 Federal Tax Lien with the Marin County Assessor-Recorder 22 Clerk’s office for an unpaid assessment of $957,146.40 against 23 Spouse. See Exhibit 2 appended to the first supplemental 24 declaration of Mahana K. Weidler (dkt. 113). Spouse paid a 25 portion of the assessed amount, but thereafter unsuccessfully 26 sued the United States for a refund in the U.S. Court of 27 Federal Claims. Id. at 4. 28 -2- 1 The United States filed a counterclaim in the Court of 2 Federal Claims for the balance of the assessments, prevailed at 3 trial, and was awarded a judgment of $1,514,140.14 plus 4 statutory interest against Spouse on September 3, 2009 (the 5 “Judgment”). See Judgment, Brinskele v. United States of 6 America, No. 1:02-cv-00911-NBF (Cl. Ct. Sept. 3, 2009). Spouse 7 appealed the Judgment but lost. See Brinskele v. United 8 States, 397 F. App'x 662 (Fed. Cir. 2010). 9 The United States recorded an abstract of the Judgment in 10 Marin County on June 23, 2011. See Claim Objection at 4; see 11 also Certified Abstract of Judgment (appended to the Motion at 12 dkt. 98-7 and appended to the first supplemental declaration of 13 Mahana K. Weidler at dkt. 113). The recorded abstract 14 indicated that, pursuant to 26 U.S.C. § 3201, its filing 15 created a lien (the “Judgment Lien”) on all real property of 16 Spouse that has priority over all other liens or encumbrances 17 which are perfected later in time. The Judgment Lien is 18 effective, unless satisfied, for a period of 20 years (i.e., 19 until June 23, 2031) and may be renewed by filing a notice of 20 renewal. See id; see also 26 U.S.C. § 3201. 21 On April 23, 2012, Spouse quit-claimed his interests in 22 certain real property located in Nicasio, California (the 23 “Property”) to Debtor. Debtor values that Property at 24 $1,595,000.00 on her schedules. 25 Separately, an IRS tax account transcript dated April 20, 26 2020, pertaining to Spouse (dkt. 106-1) reflects a “removed 27 lien” in the amount of $0.00 from Spouse’s account on January 28 -3- 1 27, 2012. See Transcript at dkt. 106-1, pg. 29 of 72. The 2 type of lien is not disclosed on the transcript, but counsel 3 for the IRS indicated in its response and at the hearing that 4 it pertains to the 2002 tax lien, and not to the Judgment Lien. 5 Counsel for Debtor conceded at the hearing that the nature of 6 the “removed lien” has been clarified and the removal of the 7 lien reflected on the tax transcript is unrelated to and does 8 not affect the Judgment Lien. 9 Debtor filed this chapter 11 case on February 23, 2018 and 10 seeks a judicial determination through the cross-motion that 11 the Judgment Lien is unenforceable against the Property as a 12 matter of law and undisputed fact. Conversely, the IRS seeks 13 summary judgment that its Judgment Lien remains enforceable 14 even if Debtor now holds title to the Property owned by Spouse 15 at the time the IRS recorded the Judgment Lien. For the 16 reasons set forth below, the court concludes that under 17 governing law, the IRS must prevail. 18 III. STATEMENT OF ISSUES 19 A. Is the Judgment Lien enforceable against the 20 Property? 21 B. Is Debtor barred by issue or claim preclusion from 22 challenging the merits of the IRS’s Judgment 23 against Spouse? 24 IV. DISCUSSION 25 A. Enforceability of the Judgment Lien 26 The record unquestionably shows that the Judgment Lien 27 itself remains on the real property records of the Marin County 28 -4- 1 Recorder’s Office and has not been cancelled, revoked, or 2 otherwise rendered ineffective. 3 The Judgment against Spouse created the enforceable 4 Judgment Lien when IRS recorded its abstract of judgment, as 5 provided in 26 U.S.C. § 3201(a): 6 (a) Creation. -- A judgment in a civil action shall create a lien on all real property of a judgment 7 debtor on filing a certified copy of the abstract 8 of the judgment in the manner in which a notice of tax lien would be filed under paragraphs (1) 9 and (2) of section 6323(f) of the Internal Revenue Code of 1986. A lien created under this 10 paragraph is for the amount necessary to satisfy 11 the judgment, including costs and interest. 12 Section 6323(f) of the Internal Revenue Code, in turn, requires 13 a notice of lien to be filed in “one office within the State or 14 the county (or other governmental subdivision), as designated 15 by the laws of such State, in which the property subject to the 16 lien is located.” 17 As noted in subsections (b) and (c) of 26 U.S.C. § 3201, 18 the Judgment Lien created has priority over any later-perfected 19 encumbrances and is effective for 20 years, subject to renewal. 20 Most importantly, such a judgment lien “shall be released on the 21 filing of a satisfaction of judgment or release of lien in the 22 same manner as the judgment is filed to obtain the lien.” 23 26 U.S.C. § 3201(d)(emphasis added). No such release has been 24 recorded in accordance with Internal Revenue Code § 3201(d).

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Related

Brinskele v. United States
73 Fed. Cl. 227 (Federal Claims, 2006)
Brinskele v. United States
88 Fed. Cl. 334 (Federal Claims, 2009)
Brinskele v. United States
397 F. App'x 662 (Federal Circuit, 2010)

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Rebecca Brown Brinskele, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-brown-brinskele-canb-2021.