MEMORANDUM AND ORDER
MAZZONE, District Judge.
This is an action to recover unpaid federal income taxes. Defendants are Luigi M. and Diane J. DiFonzo. The United States asserts that Luigi DiFonzo owes unpaid taxes for the years 1973 through 1977 and that Luigi and Diane DiFonzo together owe an unpaid tax for the year 1980; the government also seeks penalties and interest. The DiFonzo's vigorously litigated the...
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