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IN RE ESTATE OF HARLESS

No. CIV. A. 98-1072-RV-S.

98 F.Supp.2d 1337 (2000)

In the Matter of the ESTATE OF Larry J. HARLESS, Deceased Maurine K. Harless, Administratrix of the Estate of Larry J. Harless, Petitioner, v. United States of America, Respondent.

United States District Court, S.D. Alabama, Southern Division.

May 23, 2000.

Attorney(s) appearing for the Case

William T. McGowin, IV, Mobile, AL, for Larry J. Harless.

Bradley R. Byrne, Mobile, AL, William T. McGowin, IV, McRight, Jackson, Myrick & Moore, LLC, Mobile, AL, for Maurine K. Harless.

William R. Sawyer, U.S. Atty. Office, Mobile, AL, Christopher M. Pietruszkiewicz, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, DC, for U.S.

MEMORANDUM OPINION AND ORDER

VOLLMER, District Judge.

This matter comes before the court on cross-motions for summary judgment by petitioner Maurine Harless, as administratrix of the estate of Larry J. Harless, and respondent United States as to whether a divorce judgment recorded in 1992 takes priority over a federal tax lien filed in 1996. After carefully reviewing the law and considering the submissions of the parties,1

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