MEMORANDUM OPINION AND ORDER
ZIRPOLI, District Judge.
On or about March 24, 1973, the defendant, Franklin L. McNulty, won the Irish Hospitals Sweepstakes. He collected 50,000 Irish pounds, or $128,410 at the prevailing rate of exchange. Defendant soon learned, however, that he had a silent partner which would claim its share of the prize. That partner was the Internal Revenue Service, whose interest defendant sought to defeat by collecting his winnings in...
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