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  5. 848 F.Supp. 1096 (1994)
 

U.S. v. BRYNES

Civ. A. No. 92-0018-T.

848 F.Supp. 1096 (1994)

UNITED STATES of America v. Howard A. and Marjorie E. BRYNES.

United States District Court, D. Rhode Island.

March 25, 1994.

Attorney(s) appearing for the Case

Everett C. Sammartino, U.S. Attorney's Office, Providence, RI, George P. Elipoulos, U.S. Dept. of Justice, Tax Div., Washington, DC, for plaintiff.

Gerard McG. DeCelles, Providence, RI, for Howard A. Brynes.

Alan T. Dworkin, Warwick, RI, for Marjorie E. Brynes.

DECISION AND ORDER

TORRES, District Judge.

This is an action brought pursuant to 26 U.S.C. § 7403 to reduce a federal tax assessment against Howard A. Brynes to judgment and to foreclose what the government contends is a lien on certain real property formerly owned by Howard and his wife, Marjorie. The issues presented are whether the property in question is subject to a tax lien and, if so, whether the United States should be permitted to foreclose...

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