MEMORANDUM OPINION
JOHNSTONE, Chief Judge.
This matter is before the Court on cross-motions for summary judgment filed by Plaintiff United States of America (the Government), Defendant Jane Wood (Mrs. Wood), and Defendant Ina B. Johnson (Mrs. Johnson). The Government brings suit under the internal revenue laws of the United States, 26 U.S.C. §§ 1-9602, to collect unpaid taxes, interest, and penalties owed by Defendant Charles Wood (Mr. Wood) through...
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