OPINION
POLLACK, District Judge.
Plaintiff, the United States of America, moves pursuant to Fed.R.Civ.P. 56 for summary judgment of foreclosure of liens and sale of the real property of defendant, Harry Martin. The liens derive from income tax jeopardy assessments issued on April 17, 1961 relating to the tax years 1958 and 1959. A money judgment against Martin based on the same jeopardy assessments was
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