MEMORANDUM OPINION AND ORDER
BUCKLO, District Judge.
The United States of America brought this action to reduce federal income tax assessments to judgment against Stanley J. Szopa and Sophie A. Szopa. The United States moves for summary judgment against the Szopas for a stipulated amount of unpaid federal income tax, interest, and statutory additions owed by the Szopas. The Szopas also move for summary judgment, arguing that their income tax liability...
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