No. 12-3398.

725 F.3d 623 (2013)

In re Patrick J. RYAN, Debtor-Appellant. Patrick J. Ryan, Plaintiff-Appellant, v. United States of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 8, 2013.

Attorney(s) appearing for the Case

Jonathan D. Parker (argued), Attorney, Geraci Law LLC, Chicago, IL, for Debtor-Appellant.

William Elwell , Attorney, Internal Revenue Service, IRS Tax Division, Carina C. Federico , Attorney, Department of Justice, Tax Division, Rachel I. Wollitzer (argued), Bridget M. Rowan , Attorneys, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellee.

Before RIPPLE, ROVNER, and WILLIAMS, Circuit Judges.

ROVNER, Circuit Judge.

Patrick James Ryan failed to pay his federal income taxes for 2006, 2007, 2008, 2009, and 2010, resulting in outstanding liabilities totaling at least $136,898.93. In January 2011, pursuant to Internal Revenue Code 26 U.S.C. § 6323, the IRS recorded a notice of federal tax lien against Ryan's possessions with the Cook County Recorder of Deeds with respect to the liabilities for 2006-09.

On August 23, 2011, Ryan filed a voluntary...

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