Trustees of Dennis Pines Condominium Trust of Dennis v. Patten et al

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IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
TRUSTEES OF DENNIS PINES 	)
CONDOMINIUM TRUST OF DENNIS, 	)
)
Plaintiffs, 	)
)
v. 	)
)
EDWARD T. PATTEN, 	)
DARLENE K. PATTEN, 	)
CITIZENS BANK, N.A. f/k/a RBS Citizens, 	)
N.A., and 	)
UNITED STATES OF AMERICA, 	)
)
Defendants. 	)
)
UNITED STATES OF AMERICA, 	)
)
Counterclaim Plaintiff, 	)
)
v. 	)
)
TRUSTEES OF DENNIS PINES 	)
CONDOMINIUM TRUST OF DENNIS, 	)
EDWARD T. PATTEN, 	)
DARLENE K. PATTEN, 	)
CITIZENS BANK, N.A. f/k/a RBS Citizens, 	)
N.A., 	)
and TOWN OF DENNIS, MASSACHUSETTS, )
)
Counterclaim Defendants. 	)
Case No. 1:24-cv-10808-AK
FINAL JUDGMENT
Upon Counterclaim Plaintiff United States of America’s Motion for Summary Judgment,
and the Court having found that such motion should be granted, final judgment is entered, as
follows:
1. 	Counterclaim Plaintiff United States of America’s motion is GRANTED.
Case 1:24-cv-10808-AK Document 140 Filed 03/19/26 Page 1 of 2

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2. 	The United States has valid and subsisting tax liens, pursuant to 26 U.S.C. § 6321,
upon all property and rights to property of Edward T. Patten and Darlene K. Patten, including the
real property located at 1146 Route 134, Unit 6D, Dennis, MA (the “Property”).
3. 	Judgment shall enter in favor of the United States and against all Counterclaim
Defendants, enforcing the federal tax liens securing Edward T. Patten’s tax liabilities (including
all applicable penalties and interest) for tax years 2012-2013 and Edward T. Patten’s and Darlene
K. Patten’s tax liabilities (including all applicable penalties and interest) for their joint tax years
2014-2017, as described in the counterclaim, pursuant to 26 U.S.C. § 7403 against the real
property located at 1146 Route 134, Unit 6D, Dennis, MA (the “Property”), by the sale of the
entire Property in a judicial sale (including by a receiver if requested by the United States), free
and clear of all rights, titles, claims, liens, and interests of the parties, including any rights of
redemption, with the proceeds of the sale distributed in accordance with an agreement between
and among the Counterclaim Plaintiff United States and the Counterclaim Defendants Citizens
Bank, N.A., and Trustees of Dennis Pines Condominium Trust of Dennis (Doc. 33).
IT IS SO ORDERED, ADJUDGED, and DECREED:
DATED:
Judge Angel Kelley
United States District Judge
/s/ Angel Kelley	March 19, 2026
Case 1:24-cv-10808-AK Document 140 Filed 03/19/26 Page 2 of 2