MEMORANDUM OPINION AND ORDER
MUSGRAVE, Judge.
I. Introduction
This case comes before the Court on defendant's motion for partial summary judgment. The government seeks to recover penalties from Yoel Neman for an allegedly fraudulent entry of fabric falsely declared as the product of Japan, entered on September 26, 1983. Yoel Neman claims that Entry No. 83-438352-4 should be time barred by 19 U.S.C. § 1621 because the entry was filed on September...
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