ORDER AND OPINION
LEISURE, District Judge:
FACTUAL BACKGROUND
On or about April 26, 1982, the Internal Revenue Service (the "IRS"), pursuant to 26 U.S.C. § 6201(a), made an assessment in the amount of $20,655.71 against Lou Barretto ("Barretto") for the taxable year ending December 31, 1976. That assessment represented federal income taxes owed by Barretto, plus interest and statutory additions. The United States of America (the "Government...
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