OPINION ON MOTIONS FOR SUMMARY JUDGMENT
BREWSTER, District Judge.
The United States of America (Government) brought separate suits against Billie Sol Estes and wife, Patsy D. Estes, seeking a personal judgment against each of them for amounts they owed it as a result of assessments for certain income taxes, penalties and interest for the years 1959, 1960, 1961 and 1962, plus accrued interest as provided by law. Those suits were consolidated into this one...
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