OPINION AND ORDER
LATCHUM, District Judge.
The United States instituted this civil action on October 1, 1970 to reduce to judgment an assessment against the defendant, Joseph M. Donlon ("Donlon"), for unpaid federal wagering excise taxes. Jurisdiction exists by virtue of 26 U.S.C. § 7402(a) and 28 U.S.C. §§ 1340 and 1345.
The relevant facts are as follows: On October 2, 1964 the Government purportedly made an assessment against Donlon...
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