ORDER
HOLLAND, District Judge.
This action was brought under 26 U.S.C. §§ 7401 and 7403 to reduce to judgment an assessment of federal income taxes allegedly owed by Defendants for the years 1971, 1972, and 1973. Now before the Court is the stipulation of the parties that the case be submitted for decision without trial based on the present record.
As noted in the Court's order of October 8, 1985, the threshold determination here is whether...
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