Boyce

ORDER: (1) GRANTING THE GOVERNMENT’S RENEWED MOTION FOR SUMMARY JUDGMENT AND ENTRY OF JUDGMENT ON THIRD CAUSE OF ACTION; (2) DENYING THE BOYCES’ MOTIONS FOR SUMMARY JUDGMENT AND QUIET TITLE, TO AMEND THE ANSWER, TO STRIKE EXHIBITS AND REOPEN DISCOVERY; AND (3) GRANTING THE BOYCES’ EX PARTE APPLICATION

This matter came on regularly for a hearing on the: (1) Government’s renewed motion for partial summary judgment; (2) Government’s motion for default judgment and judgment by stipulation on its third cause of action for foreclosure of federal tax liens; (3) Defendants’ James M. Boyce, Jr. a.k.a. James M. Boyce (“James Boyce”) and Shelley A. Boyce (“Shelley Boyce”) (collectively referred to as “the Boyces”) motion for summary judgment and quiet title; and (4) the Boyces’ motion to amend the answer. Henry C. Darmstadter, of the U.S. Department of Justice Tax Division appeared for Plaintiff United States, and Richard Shepard of the Shepard Law Offices appeared for Defendants.

FACTUAL BACKGROUND

I. Facts Relevant to the Tax Assessments.

For the years 1979 to 1981, James Boyce and Shelley Boyce filed Forms 1040 that purported to be joint federal income tax returns as husband and wife,…