Court orders sale of Kentucky home to satisfy $4.2 million federal tax lien
United States v. Joel, No. 3:13-cv-1102-BJB-LLK, 2025 BL 470084
The court approved a forced sale of a Louisville property to collect more than $4.2 million in unpaid federal income taxes, appointed a receiver, and authorized eviction if occupants do not leave.
Holding
The court granted the government’s motion to sell real property in Louisville, Kentucky, enforced federal tax liens, appointed a receiver to manage and sell the property, and set detailed terms for eviction, sale, and distribution of proceeds.
Why It Matters
Confirms broad federal authority to force judicial sales under §§ 7402 and 7403.
Shows how courts handle occupied residences subject to federal tax liens.
Highlights the use of receivers to manage, secure, and sell property.
Reinforces that federal courts can cut off redemption rights in lien enforcement sales.
Timeline
May 6, 2013. Federal tax liabilities were assessed against Larry Joel.
Prior judgment entered fixing liability at over $4.2 million.
The government moved for an order of sale and appointment of a receiver.
December 30, 2025. The court granted the motion and issued the sale order.
Key Facts
Property: 2502 Champion Lakes Court, Louisville, Kentucky.
Taxpayer: Larry H. Joel.
Federal tax liability: $4,236,116.43 plus statutory additions.
Receiver appointed: Kristin Lally of Re/Max Properties East.
Property will be sold free and clear of liens and interests.
Statutory Framework
§7402(a), which grants courts broad powers to enforce internal revenue laws.
§7403(b), which authorizes judicial sales to satisfy federal tax liens.
§6323(b)(6), which gives limited priority to certain local property tax claims.
Arguments
Government argued:
Federal tax liens attached to the property.
The sale was necessary to satisfy long-standing unpaid tax liabilities.
Appointment of a receiver was required to secure and market the property.
Defendants argued:
Objections focused on valuation, process, and sale terms.
Sought limits on pricing discretion and sale mechanics.
Court’s Reasoning
Federal tax liens remained unpaid for more than a decade.
Judicial sale is an appropriate enforcement tool under the Code.
A neutral receiver ensures orderly sale and preservation of value.
Eviction authority is necessary to prevent interference or waste.
A sale free and clear protects buyers and maximizes marketability.
Distribution priorities follow the Internal Revenue Code.
Court oversight over pricing and contracts protects all parties.
Forward-Looking Implications
Occupied residences are not immune to forced tax lien sales.
Courts may authorize aggressive enforcement, including eviction.
Receivers can be given wide discretion, subject to court approval.
Taxpayers face limited leverage once judicial sale authority is granted.
Result
The court ordered the sale of the Louisville property, appointed a receiver, authorized eviction if necessary, and directed that sale proceeds be used to satisfy federal tax liabilities.
The Takeaway
Once the government secures judicial sale authority, courts will move decisively to liquidate property, remove occupants, and apply proceeds to unpaid taxes with little room for delay or obstruction.