However, "A certificate of release, while conclusive that the lien is extinguished, does not establish that the underlying tax liability has been paid or is not owed." In re Frank, 2011 WL 860684, at * 3 (Bankr. M.D.N.C. Mar. 9, 2011); United States v. Springer, 2010 WL 830614, * 9 (N.D. Okla. Mar. 3, 2010) (explaining that a certificate of release "does not establish that the underlying tax liability has been paid"). Defendants have not presented evidence indicating that the government's assessments are inaccurate.