OPINION
BATTISTI, District Judge:
This action has been submitted for decision on the basis of a "Stipulation of Facts." This stipulation resolves all but one of the issues raised by the pleadings.
The sole issue remaining is whether the plaintiff is barred by 26 U.S.C. § 6502(a) from collecting a certain gambling excise tax assessment. The facts relative to that issue are set forth in paragraphs 3 through 9 of the Stipulation of Facts. They...
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