MEMORANDUM
RAMBO, Chief Judge.
Before the court is a motion for summary judgment filed by Defendant/Third-Party Plaintiff United States of America against Third-Party Defendant George S. Updegraff. The issues have been briefed, and the matter is ripe for disposition.
I. Background
The instant case arises from tax assessments made by Defendant/Third-Party Plaintiff United States ("the Government") against Plaintiff...
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