MEMORANDUM OPINION AND ORDER
KYLE, District Judge.
Introduction
Before the Court is the Plaintiff United States of America's ("the United States") Motion for Summary Judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure. The United States filed suit in this Court pursuant to sections 7401, 7402, and 7403 of the Internal Revenue Code ("the Code"), 26 U.S.C. §§ 7401-7403. In Count I of the Complaint, the United States seeks...
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