United States First Circuit

In a suit by taxpayers alleging that they had been deprived of their statutory right to a Collection Due Process hearing with respect to federal tax liens filed against them, summary judgment for the US is affirmed where the government's affidavits were sufficient, absent contrary evidence, to show that notification letters were sent to the taxpayers in a timely manner.

Appellate Information

• Decided 04/03/2007
• Published 04/03/2007

Judges

• BOUDIN, Chief Judge., Before BOUDIN, Chief Judge, CAMPBELL, Senior Circuit Judge, and HOWARD, Circuit Judge.

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Timothy J. Burke with whom Burke & Associates was on brief for appellants.


• For Appellees:
  
• John Schumann, Tax Division, Department of Justice, with whom Eileen J. O'Connor, Assistant Attorney General, Michael J. Sullivan, United States Attorney, and Jonathan S. Cohen, Tax Division, Department of Justice, were on brief for appellee.