Vacante

MEMORANDUM DECISION RE DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT (Doc. 105) AND MOTION TO DISMISS (DOC. 124); PLAINTIFF UNITED STATES OF AMERICA’S MOTION FOR PARTIAL SUMMARY JUDGMENT (Doc. 119)

I. INTRODUCTION.

Plaintiff United States filed this action to reduce federal tax assessments to judgment and foreclose federal tax liens on real property on June 10, 2008. The tax assessments at issue are against husband and wife Frank and Ute Vacante and their alleged alter egos, Central Valley Insurance Services, Inc. (“CVIS”), and Instant Services, Inc.

Before the Court for decision are several motions. The United States moves for summary judgment against Defendants Frank Vacante and Ute Vacante, proceeding pro se, seeking to reduce to judgment individual tax liabilities for tax years 2000 and 2004. In addition to reducing to judgment the individual tax liabilities assessed against Frank and Ute Vacante, Plaintiff moves to reduce to judgment Frank Vacante’s Form 941 Employment Tax Liabilities for the tax periods ending June 30, 1993, September 30, 1993, December 31, 1993, March 31, 1994, June 30, 1994, September 30, 1994, and December 31, 1994; Plaintiff also seeks to reduce to judgment…