Berg

MEMORANDUM OPINION AND ORDER

I. INTRODUCTION

On May 4, 1998, the United States filed suit to enforce various tax liens recorded against real property owned by Defendant Gordon D. Berg. (Doc. 1) The liens resulted from Berg’s failure to pay federal employment taxes. Specifically, as an employer, he failed to pay Federal Insurance Contribution Act Taxes (hereinafter Form 941 or FICA taxes) for various tax periods between the tax period ending March 31,1979 and the tax period ending December 31, 1984 (PL Facts II3 - 86); and Federal Unemployment Tax Act taxes (hereinafter Form 940 or FUTA taxes) for various tax periods between the *541 tax periods ending December 31, 1978 and December 31,1984 (PL Facts f 88 - 114). In addition, as a result of the unpaid federal employment tax liability, a trust fund recovery penalty was assessed against Berg. (Pl. Facts f 116). The amounts in question are as follows:

To collect these taxes, Plaintiff filed liens on various tracts of real property owned by Berg: one in Modesto and two in Fresno, referred to as the “Church Avenue” and the “Barcus Avenue” properties. Named as defendants were all persons and entities having an interest in the real…