United States v. Mahoney

CourtDistrict Court, E.D. Missouri
DecidedMarch 29, 2022
Docket4:21-cv-01245
StatusUnknown

This text of United States v. Mahoney (United States v. Mahoney) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Mahoney, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No. 4:21 CV 1245 CDP ) JAMES T. MAHONEY, et al., ) ) Defendants. )

MEMORANDUM AND ORDER

Plaintiff United States of America moves for default judgment against defendants James T. Mahoney; the Missouri Department of Revenue; Beneficial Financial I, Inc., as successor by merger to Beneficial Missouri, Inc.; and Portfolio Recovery Associates, LLC, in this action brought under 26 U.S.C. § 7403 to enforce federal tax liens and a criminal restitution lien to satisfy defendant Mahoney’s federal tax liabilities. I will grant the United States’ motion and enter default judgment against these defendants. In view of the entry of default judgment and the resulting authority granted to the United States to enforce federal tax liens against defendant Mahoney’s property, I will order the United States to submit a proposed Order for Sale of Property with a proposed distribution of the proceeds of the sale. Background The United States filed this civil action on October 18, 2021, seeking to: (1)

reduce to judgment federal income tax assessments against defendant James T. Mahoney; (2) enforce federal tax liens and a criminal restitution lien against real property located at 11327 Manchester Road, Kirkwood, Missouri 63122 (the

Property) to satisfy, in part, Mahoney’s federal tax liabilities; (3) obtain an order authorizing the sale of the Property; and (4) have the proceeds from the sale distributed in amounts determined by the Court. The complaint alleges that Mahoney filed late federal income tax returns for

each tax year from 1999 through 2010 and from 2015 through 2017, reporting unpaid tax due; filed federal income tax returns for each tax year from 2011 through 2014, reporting unpaid tax due; and that as of October 5, 2021, was

indebted to the United States in the total amount of $1,103,973.19 for the unpaid federal income taxes, plus assessed interest and penalties. The complaint also alleges that, pursuant to a criminal judgment entered July 9, 2014, against Mahoney on his conviction for failure to file a tax return for tax year 2007,

Mahoney was ordered to pay restitution in the amount of $186,554.64; and that as of October 5, 2021, was indebted to the United States in the total amount of $226,107.10, representing his outstanding restitution debt, plus accrued interest

and statutory penalties, minus payments and other credits. The complaint further alleges that the Secretary of the Treasury made assessments on the above noted amounts due and that the United States provided

Mahoney notice of these assessments and made demands for payment. The complaint alleges that Mahoney’s continued failure to pay resulted in federal tax liens in favor of the United States, and the United States asserts it is entitled to

enforce the liens against the Property owned by Mahoney in Kirkwood, Missouri. The United States asks for judgment against Mahoney in the amount of his indebtedness and for an order that the Property be sold, with the Court determining the priories of claims or liens encumbering the Property and directing that the

proceeds of the sale be distributed in accordance with that determination. In addition to naming defendant Mahoney as the delinquent taxpayer, the United States names several defendants as entities who may claim an interest in the

Property, namely the Missouri Department of Revenue; Beneficial Financial I, Inc.; Portfolio Recovery Associates, LLC; and St. Louis County, Missouri. See 26 U.S.C. § 7403(a), (b). St. Louis County waived service of process and answered the complaint on December 20, 2021. All other defendants were served with

summons and complaint in this action but did not answer the complaint or otherwise appear in this matter. The Clerk of Court entered default against these defendants on January 26, 2022.

The United States now moves for entry of default judgment against Mahoney for his tax liabilities due as set forth in the complaint, plus interest and penalties as of February 24, 2022, for a total of $1,116,826.23. The United States

also seeks an Order that valid federal tax liens exist on the Property and that those liens may be enforced by Order of Sale of the Property to satisfy the judgment. Finally, the United States seeks default judgment against the Missouri Department

of Revenue; Beneficial Financial I, Inc.; and Portfolio Recovery Associates, LLC, decreeing that these defendants have no claimed interest in the Property and thus that the Property may be sold free and clear of all liens, claims, and interests they may have had.

In support of its motion, the United States has submitted a declaration of an Internal Revenue Service advisory revenue officer confirming the amount of Mahoney’s indebtedness; certificates of assessments and payments for all relevant

tax years, with entries of statutory notices of balance due and intent to levy; an exhibit showing the calculation of Mahoney’s federal income tax liabilities; notices of federal tax liens dated August 18, 2015, January 8, 2016, and April 23, 2019; a certificate of restitution-based assessment dated December 8, 2014, and subsequent

payments, with entries of statutory notices of balance due and intent to levy; notice of restitution lien dated July 17, 2014, and notice of federal tax lien thereon dated July 14, 2015; and a general warranty deed and quit claim deeds demonstrating

Mahoney’s ownership interest in the Property. Discussion Where default has been entered, the allegations of the complaint are taken as

true, except as to the amount of damages; it then “remains for the court to consider whether the unchallenged facts constitute a legitimate cause of action, since a party in default does not admit mere conclusions of law.” Murray v. Lene, 595 F.3d 868,

871 (8th Cir. 2010) (internal quotation marks and citation omitted). Count I – Reduce Tax Assessments to Judgment “Tax assessments made by the IRS are presumed correct and the taxpayer bears the burden of proving, by a preponderance of the evidence, that the

assessment is erroneous.” North Dakota State Univ. v. United States, 255 F.3d 599, 603 (8th Cir. 2001). “If the taxpayer does not pay the amount assessed, then the amount automatically becomes a tax lien on all property belonging to the

taxpayer . . . .” Pagonis v. United States, 575 F.3d 809, 812 (8th Cir. 2009). See also United States v. Isagba, No. 5:17-CV-93-OC-32PRI, 2017 WL 6539049, at *1 (M.D. Fla. Dec. 2017) (entering default judgment reducing federal tax liens to judgment and ordering sale of real property); United States v. Tobey, No. 16-CV-

4096 (JRT/LIB), 2017 WL 6883880. At *3 (D. Minn. Dec. 19, 2017), report and recommendation adopted, 2018 WL 344977 (D. Minn. Jan. 9, 2018); United States v. Kuyper, No. 4:11CV4170, 2013 WL 5755587, at 3 (D.S.D. Oct. 23, 2013), aff’d,

577 F. App’x 626 (8th Cir. 2014) (allowing for default judgment for tax liability currently due, even though the complaint stated a liability through a certain earlier date, where the current liability was supported by current documentation).

The record supports the United States’ request for relief against defendant Mahoney for unpaid federal income taxes.

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Related

United States v. Rodgers
461 U.S. 677 (Supreme Court, 1983)
United States v. National Bank of Commerce
472 U.S. 713 (Supreme Court, 1985)
Pagonis v. United States
575 F.3d 809 (Eighth Circuit, 2009)
Murray v. Lene
595 F.3d 868 (Eighth Circuit, 2010)
United States v. Duane L. Kuyper
577 F. App'x 626 (Eighth Circuit, 2014)

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United States v. Mahoney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-mahoney-moed-2022.