In an action by the government against defendant-taxpayers to reduce to judgment federal income tax liabilities, dismissal of defendants' claims of improper notice based on their attorney's supposed failure to receive notice of tax liens and the IRS's improper failure to consider an innocent spouse defense, is affirmed as the claims are foreclosed by res judicata and are without merit.
Appeal from the United States District Court for the District of Massachusetts
Decided December 14, 2009
Before: Boudin, Howard and Tashima, Circuit Judges
Opinion by Tashima, Circuit Judge
For Appellant: Timothy J. Burke
For Appellee: John Schumann, Tax Division, U.S. Department of Justice