Bryan

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, No. 2:22-cv-01962-DJC-AC 12 Plaintiff, 13 v. ORDER 14 MARK LINN BRYAN, et al., 15 Defendants. 16 Plaintiff United States filed this action to reduce federal tax assessments against Defendant Mark L. Bryan to judgment and to foreclose federal tax liens on a residential property owned by Mr. Bryan and his former spouse, Lori Bryan. Before the Court is the United States’ Motion for Summary Judgment pursuant to Federal Rule of Civil Procedure 56. (ECF No. 201.) Since the Court heard argument in the United States’ Motion, Mr. Bryan moved for leave to amend his counterclaims (ECF No. 227) and filed a Motion to Dismiss (ECF No. 229). For the reasons stated below, the Court grants the United States’ Motion and denies Mr. Bryan’s motions. BACKGROUND Mark L. Bryan is a United States citizen who has lived in California his entire life. (Defendant Lori Bryan’s Response to Plaintiff’s Statement of Undisputed Facts…