MEMORANDUM OPINION AND ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT, AND DENYING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
GADOLA, District Judge.
In this case the plaintiff United States has brought this civil action pursuant to 26 U.S.C. § 7401, seeking to reduce to judgment the federal taxes allegedly assessed against the defendant Richard Morgan. The United States seeks to recover the unpaid individual income...
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