United States District Court, D. Nevada
RICHARD E. ZUCKERMAN PRINCIPAL DEPUTY ASSISTANT ATTORNEY
GENERAL CHARLES M. DUFFY TRIAL ATTORNEY, TAX DIVISION U.S.
DEPARTMENT OF JUSTICE
ELIESON UNITED STATES ATTORNEY OF COUNSEL ATTORNEYS FOR THE
UNITED STATES OF AMERICA
ORDER OF FORECLOSURE AND JUDICIAL SALE
P. GORDON UNITED STATES DISTRICT JUDGE.
Order of Foreclosure and Judicial Sale is entered pursuant to
the provisions of 28 U.S.C. §§ 2001 and 2002 and 26
U.S.C. §§ 7402 and 7403. The Court hereby orders as
July 8, 2019, summary judgment was entered against Raymond W.
Crihfield and Lisa A. Crihfield (hereafter “the
Crihfields”) regarding their 2003, 2004, 2006, 2007,
2009, 2010 and 2011 federal income tax liabilities.
See ECF #32. The aggregate amount of income tax
liabilities owed by the Crihfields for those years is $326,
664.32 as of October 19, 2018, plus statutory interest
accruing thereafter. See ECF #17, at page 8 (¶
31) and ECF #20, at ¶¶ 49-55.
its July 8, 2019 order, the Court also granted summary
judgment regarding the United States' claim that it could
foreclose its federal tax liens arising from the IRS
assessments made against the Crihfields against two real
properties that have been referred to in this matter as the
“Hardy” and “Windsong” properties
(also referred to below as the “subject
properties”). See ECF #32.
Hardy property is located at 3140 West Hardy Lane, Pahrump,
Nevada 89048 and also is legally described as follows:
Parcel one Hundred Twenty-four (124) of CHARLESTON PARK
RANCHOS UNIT NO. 1, recorded September 18, 1959 as File No.
32752 in Book C of Surveys, Page 279, Nye County, Nevada
EXCEPTING THEREFROM all of its right, title and interest in
and to all of the minerals, including gas, coal, oil and oil
shales, as disclosed by Deed recorded December 11, 1959 as
Document No. 33209 in Book 36, Page 221, Official Records,
Nye County, Nevada. Excepting therefrom the mobile home
located thereon. Assessor's Parcel Number: 28-682-01.
Windsong property is located at 3021 West Windsong Lane,
Pahrump, Nevada and also is legally described as follows:
Lot Thirty-Three (33) of GOLDEN SPRING RANCH UNIT NO. 1 as
shown by map thereof recorded May 20, 1963 as File No. 44480
in the Office of the County Recorder of Nye County, Nevada.
Assessor's Parcel Number: 41-402-01.
United States has valid and subsisting tax liens on all
property and rights to property of the Crihfields, including
the Hardy and Windsong properties, arising from the
assessments described in paragraph 48 of Complaint in this
action, which tax liens are effective as of the dates of
those assessments. The United States further protected its
liens by filing various Notices of Federal Tax Lien in the
Nye County, Nevada, Recorder's Office.
Section 7403 of Title 26 (U.S.C.) entitles the United States
to enforce its liens against the Hardy and Windsong
properties in order to apply the proceeds towards the federal
tax liabilities of the Crihfields.
United States' federal tax liens against the Hardy and