Novelli

ORDER GRANTING PARTIAL SUMMARY JUDGMENT ON INCOME TAX LIABILITIES AND TFRP LIABILITIES OF RAYMOND G. NOVELLI AND DENYING SUMMARY JUDGMENT ON TFRP LIABILITIES OF MARLIES NOVEL-LI, AND FORECLOSURE

Before the Court are Plaintiff United States’ (“the government”) motions for (1) Partial Summary Judgment on Income Tax Liabilities (Docket No. 40); (2) Partial Summary Judgment on Trust Fund Recovery Penalty (“TFRP”) Liabilities of Raymond G. Novelli (Docket No. 44); (3) Partial Summary Judgment on TFRP Liabilities of Marlies Novelli (Docket No. 48); and (4) Partial Summary Judgment on Foreclosure (Docket No. 51). After considering the moving, opposing, and replying papers, oral argument, and for the reasons set forth below, the Court GRANTS the motions for Partial Summary Judgment on Income Tax Liabilities and on TFRP Liabilities of Raymond G. Novelli, and DENIES the motions for Partial Summary Judgment on the TFRP Liabilities of Marlies Novelli and on Foreclosure.

I. BACKGROUND

This suit involves a variety of tax liabilities owed by Defendants Raymond G. Nov-elli and Marlies Novelli (“the Novellis”), and an attempt by the government to foreclose on real property at 7 Rue Villars,…