Scott
United States v. Scott
Opinion
Opinion
Gonzalez, J.
ORDER (1) GRANTING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT; (2) DENYING PLAINTIFF’S EX PARTE APPLICATION TO FILE A SUR-REPLY; and (3) DENYING DEFENDANT’S EX PARTE REQUEST TO FILE A SECOND SUPPLEMENTAL MEMORANDUM
Presently before the Court is plaintiffs motion for summary judgment to reduce to judgment certain tax assessments against defendant Neil Alan Scott. Additionally, both parties have filed ex parte applications seeking leave of the Court to file additional memoranda of points and authorities. For the reasons discussed below, the Court grants plaintiffs motion and denies both ex parte applications.
BACKGROUND
On October 16, 2002, plaintiff the United States of America (the “government”) brought this action against Scott to reduce to judgment certain unpaid income tax assessments, including a civil penalty. (See Compl. at ¶¶ 1, 7 and 9.) On March 3, 2003, the government moved for summary judgment.
Unless otherwise noted, the Court finds that the following facts are undisputed. The United States is seeking to collect on tax and penalty assessments for the tax years 1983 , 1985, 1988, 1989, 1992, 1993, 1996, 1997, and 1998. Scott did not file federal income tax returns for…