JUDGMENT

JOHN A. MENDEZ, District Judge.

This action came to be considered before the Court on the United States' motion for summary judgment. The issues have been considered and a decision has been rendered.

IT IS ORDERED AND ADJUDGED that the United States' Motion for Summary Judgment is granted and JUDGMENT is entered in favor of the United States and against Kenneth J. and Patricia I. Malinowski, jointly, in the amount of $2,273,527.70, plus additional interest pursuant to 28 U.S.C. § 1961(c)(1) and 26 U.S.C. § 6621, and other statutory additions from August 4, 2012; against Kenneth J. Malinowski individually in the amount of $256,274.58, plus additional interest pursuant to 28 U.S.C. § 1961(c)(1) and 26 U.S.C. § 6621, and other statutory additions from August 4, 2012; and against Patricia I. Malinowski individually in the amount of $256,037.46, plus additional interest pursuant to 28 U.S.C. § 1961(c)(1) and 26 U.S.C. § 6621, and other statutory additions from August 4, 2012.

IT IS FURTHER ORDERED AND ADJUDGED that the United States has a valid federal tax liens for the unpaid income tax assessments at issue in this action against all property and rights to property belonging to Kenneth J. Malinowski and Patricia I. Malinowski arising out of the tax periods at issue in this action;

IT IS FURTHER ORDERED AND ADJUDGED that the United States' tax liens against Kenneth J. Malinowski and Patricia I. Malinowski for federal income taxes for tax years 1998, 1999, 2000, 2001, 2002 and 2003 attached to the parcel of real property located at 6037 White Cloud Ct., Citrus Heights, CA 95621 (the "Subject Property"), and legally described as follows:

IT IS FURTHER ORDERED AND ADJUDGED that the United States's federal tax liens be foreclosed upon the Subject Property. Plaintiff shall submit a proposed Order of Sale setting forth the terms and conditions of the sale of the property.

IT IS SO ORDERED.