OPINION
ROBERT L. CARTER, District Judge.
This is an action by the United States to recover liquidated customs duties from an importer of foreign goods, Desiree International U.S.A., Ltd. ("Desiree"), and its surety, St. Paul Fire & Marine Insurance Company ("St. Paul"). The government, arguing that defendants' obligation to pay the duties in question has become final under section 514 of the Tariff Act of 1930, as amended ("Act"), 19 U.S.C. § 1514...
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