Allison

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, No. 1:20-cv-00269-DAD-HBK Plaintiff, v. ORDER GRANTING IN PART AND

DENYING IN PART PLAINTIFF’S MOTION

DIANE R. ALLISON, et al., FOR PARTIAL SUMMARY JUDGMENT Defendants. (Doc. No. 29) 16 17 Before the court is a motion for partial summary judgment filed by plaintiff, the United States of America, to reduce to judgment unpaid estate taxes by defendant the Estate of Roger L. Wilson, Sr. and to impose personal liability for the unpaid estate taxes on defendants Diane R. Allison and Sonja R. Wilson. (Doc. No. 29.) Pursuant to General Order No. 617 addressing the public health emergency posed by the COVID-19 pandemic, plaintiff’s motion was taken under submission on the papers. (Doc. No. 30.) For the reasons explained below, the court will grant in part and deny in part plaintiff’s motion.

1 The undersigned apologizes for the excessive delay in the issuance of this order. This court’s…