Memorandum and Order
SINGLETON, District Judge.
This is an action brought by the United States against the estate of Marston G. Slate, deceased, and Joanne E. Slate, administratrix, to recover a judgment for various unpaid income taxes, income withholding taxes, Federal Insurance Contribution Act (FICA) taxes, penalties and interest, for various years prior to decedent's death. Jurisdiction is predicated on 28 U.S.C. §§ 1340 and 1345 (1960...
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