MEMORANDUM OPINION
LATCHUM, Senior District Judge.
On September 18, 1984, the United States of America initiated this civil action against Jack L. Eshelman, Betty Lou Eshelman, Timothy J. Eshelman, Tammy L. Eshelman, Thomas S. Eshelman, and Dollar Dry Dock Savings Bank seeking to reduce federal income tax assessments against Jack L. Eshelman and Betty Lou Eshelman to judgment, and to foreclose its tax lien against certain real property in White Clay Creek...
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