MEMORANDUM OPINION AND ORDER
CEREZO, District Judge.
This is an action brought by the United States of America under 26 U.S.C. Sec. 7401 and 7403 to collect the unpaid tax liability of Del Valle & Del Valle, Inc. (hereinafter referred to as the taxpayer). Specifically, the suit seeks to foreclose a lien and to reduce tax liabilities to judgment. Both the plaintiff and defendant, Government Development Bank...
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