MEMORANDUM AND ORDER
WARREN, District Judge.
This action is currently before the Court on a motion for summary judgment filed on behalf of the Commissioner. After reviewing the facts of the case and the briefs prepared by both parties, the Court is of the opinion that the motion must be granted. The facts and law applicable thereto are detailed below.
Marcia and Samuel Mishelow were the joint owners of a building used for both commercial and residential...
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