ABRUZZO, District Judge.
The United States of America in this action is seeking to foreclose liens for federal income taxes against the defendants. The action against Henry E. Peelle involves the sum of $1,583,856.04 and covers the years 1944 through 1949. The action against Inez Beatty Peelle involves the amount of $757,514.98 with interest and penalties. Inez Beatty Peelle and Henry E. Peelle filed joint returns for the years 1948 and 1949. The plaintiff, in addition...
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