Court enters default judgment for IRS to collect $334,770 from Massachusetts taxpayer

United States v. Young, No. 1:24-cv-12236-JEK, 2025 BL 391589 (D. Mass. Oct. 31, 2025), Court Opinion

The federal court granted the government’s motion for default judgment against a Massachusetts taxpayer and a defunct mortgage lender, allowing the IRS to collect over $334,000 in unpaid income taxes and to enforce its liens against the taxpayer’s property.

Holding

The District Court for the District of Massachusetts determined that Paul Young’s federal income tax liabilities for 2009–2014 were assessed correctly and confirmed that the IRS’s tax liens were attached to his Lynnfield property.

Since Young and GreenPoint Mortgage Funding neither responded nor appeared, the court issued a default judgment in favor of the United States, affirming the tax debt and canceling GreenPoint’s claimed interest in the property.

Why It Matters

• Confirms that the government may obtain a default judgment to enforce tax liens when defendants fail to appear.

• Reinforces that IRS assessments carry a presumption of correctness absent contrary evidence.

• Clarifies that federal tax liens attach automatically to all of a taxpayer’s property once assessments are made.

• Demonstrates that lien enforcement actions can proceed even where multiple entities once held or claimed mortgage interests.

Timeline

• January 2003: Young acquires property at 44 Lakewood Road, Lynnfield, Massachusetts.

• 2009–2014: IRS assesses federal income tax liabilities against Young.

• August 2024: The government files a complaint to reduce the liabilities to judgment and enforce liens.

• November 2024: Amended complaint filed; Young and GreenPoint are served but do not respond.

• January–February 2025: Clerk enters defaults against both defendants.

• April 2025: Government moves for default judgment.

• October 31, 2025: Court grants the motion and enters judgment.

Key Facts

• Paul Young owes $334,770.93 in unpaid income taxes, penalties, and interest as of March 31, 2025.

• The IRS filed Notices of Federal Tax Lien with the Massachusetts Registry of Deeds.

• The case involves the Lynnfield property that Young has owned since 2003.

• GreenPoint Mortgage Funding and MERS were named due to potential mortgage interests.

• U.S. Bank, as trustee for a mortgage-backed securities trust, stipulated lien priority with the United States.

• MERS was dismissed earlier in the case for lack of interest in the property.

Statutory Framework

• 26 U.S.C. § 7402(a): Authorizes district courts to issue orders necessary to enforce internal revenue laws.

• 26 U.S.C. § 7403: Allows the United States to enforce tax liens and determine lien priorities among parties claiming an interest in the property.

• 26 U.S.C. §§ 6321–6322: Federal tax liens arise upon assessment and attach to all of a taxpayer’s property and rights to property until the liability is satisfied.

• 28 U.S.C. §§ 1331, 1340, 1345: Provide federal jurisdiction over tax and government enforcement actions.

• Fed. R. Civ. P. 55: Governs entry of default and default judgment.

Arguments

The government argued:

• Young owes unpaid income taxes for multiple years and was properly notified.

• Valid federal tax liens exist and attach to the Lynnfield property.

• GreenPoint and MERS were appropriately named due to potential conflicts of interest, but failed to appear.

• The court has jurisdiction, and the pleadings support judgment for a sum certain.

Defendants:

• Did not respond or appear; all factual allegations are deemed admitted.

Court’s Reasoning

• The United States had both subject matter and personal jurisdiction under federal tax statutes and procedural rules.

• Proper service was made on Young at his Lynnfield residence and on GreenPoint’s registered agent.

• IRS assessments are presumed correct and remain uncontested; the record establishes the amount due.

• Tax liens automatically attached to all of Young’s property when assessments were made.

• Under §7403, the United States can enforce liens against the property and extinguish any competing claims.

• GreenPoint’s default and nonappearance justify entry of judgment declaring it has no remaining interest.

• All statutory prerequisites for default judgment—jurisdiction, valid claims, and fair notice—were met.

Forward-Looking Implications

• Reinforces that the DOJ can use default proceedings to finalize tax debt enforcement when taxpayers ignore litigation.

• Highlights that lien enforcement suits can clean title against prior lenders or defunct entities.

• Serves as a reminder to financial institutions to respond promptly to lien enforcement actions to preserve any claim.

• Confirms continued judicial willingness to apply §7402 and §7403 to compel compliance and collection.

Result

Default judgment entered for the United States for $334,770.93 plus post-judgment interest, and declaration that GreenPoint Mortgage Funding, Inc. holds no right or lien in the Lynnfield property or sale proceeds.

The Takeaway

When taxpayers fail to answer enforcement suits, the government can swiftly convert IRS assessments into enforceable court judgments and clear competing property interests to satisfy unpaid tax debts.

List of Citations

• 26 U.S.C. § 7402(a) – Grants district courts authority to issue judgments and orders necessary to enforce federal tax laws.

• 26 U.S.C. § 7403(a), (c) – Authorizes the United States to enforce tax liens and determine lien priorities among claimants.

• 26 U.S.C. §§ 6321–6322 – Creates and defines the scope and duration of federal tax liens upon assessment.

• 28 U.S.C. §§ 1331, 1340, 1345 – Establish federal jurisdiction for cases involving U.S. tax enforcement and actions by the federal government.

• Fed. R. Civ. P. 4 & 55 – Establish procedures for service of process, entry of default, and default judgment.

• United States v. Fior D’Italia, Inc., 536 U.S. 238 (2002) – Confirms presumption of correctness for IRS assessments.

• United States v. Baker, 852 F.3d 97 (1st Cir. 2017) – Explains attachment of federal tax liens to all taxpayer property upon assessment.

• United States v. Cardaci, 856 F.3d 267 (3d Cir. 2017) – Recognizes district court jurisdiction over lien enforcement under §§ 7402 and 7403.

• Hannon v. City of Newton, 744 F.3d 759 (1st Cir. 2014) – Interprets breadth of federal tax lien reach under § 6321.

• United States v. National Bank of Commerce, 472 U.S. 713 (1985) – Describes the broad reach and priority of federal tax liens.

• Glass City Bank v. United States, 326 U.S. 265 (1945) – Holds that tax liens attach to every property interest of the taxpayer.

• United States v. Rye, 550 F.2d 682 (1st Cir. 1977) – Affirms courts’ power to compel payment of government liens through foreclosure.

• Brody v. United States, 243 F.2d 378 (1st Cir. 1957) – Interprets § 7402 as granting district courts broad powers to enforce tax laws.

• Universitas Educ., LLC v. Granderson, 98 F.4th 357 (1st Cir. 2024) – Establishes that defaulting parties are deemed to admit factual allegations for purposes of liability.

• Banco Bilbao Vizcaya Argentaria v. Family Restaurants, Inc. (In re Home Restaurants, Inc.), 285 F.3d 111 (1st Cir. 2002) – Sets standards for default judgment: jurisdiction, valid claim, and fair notice.

• United Elec., Radio & Mach. Workers v. 163 Pleasant St. Corp., 960 F.2d 1080 (1st Cir. 1992) – Defines scope of personal jurisdiction in federal question cases.

• United States v. LaBombard, 107 F. Supp. 2d 57 (D. Mass. 2000) – Finds valid personal jurisdiction where taxpayer served at residence within forum.

• United States v. Marullo, No. 24-cv-061-NT, 2025 WL 1424390 (D. Me. May 16, 2025) – Grants similar default judgment enforcing federal tax liens.