MEMORANDUM OPINION
WOODWARD, Chief Judge.
The above case was tried before the court without a jury on the 23rd day of March, 1983 with all attorneys and parties present. After hearing and considering the pleadings, the briefs and arguments of counsel, and the evidence at the trial, the court files this memorandum opinion which shall constitute its findings of fact and conclusions of law.
The Government is suing Mr. Irwin for the amount now claimed...
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