MEMORANDUM AND ORDER
REGAN, District Judge.
Following the September 9, 1974 conviction of plaintiff Edward Yawitz on charges of evasion of federal income taxes, the Internal Revenue Service made jeopardy tax assessments totalling several hundreds of thousands of dollars against Yawitz, his wife, and Clardel Drug Company (collectively referred to as taxpayers). Demand for payment was given and on September 16, 1974 notice of federal tax liens were duly filed...
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