Harding

BACKGROUND

21 On March 15, 2008, the government filed the instant action against defendants Alfred 22 Harding, Cheryl Harding, and the California Franchise Tax Board (“Board”). Dkt. No. 1 (Compl.). 23 The government seeks $5,402,042.51,1 plus interest, penalties, and statutory additions, in unpaid 24 joint federal income taxes. Id. at 9:14–17. In the compliant, the government sought to foreclose tax

26 1 In the complaint, the government originally sought $5,019,760.91 – Mr. Harding’s liability as of February 2018. Compl. at 6:20–22. The government later updated the amount to 27 $5,402,042.51, to reflect Mr. Harding’s alleged liability as of July 31, 2019. Mot. Default J. at 3:20– liens on two parcels of real property owned by Cheryl Harding. Id. at 10:12–17. However, the United States no longer seeks to foreclose on the tax liens, since it settled those claims with Ms. Harding, who owns the attached property. Mot. Default J. at 2:23–24. The government named the Board as a defendant out of an abundance of caution, to prevent the Board from claiming an interest in the attached property. Id. at 3:2–4. The government alleges…