MEMORANDUM AND ORDER
ATLAS, District Judge.
This tax collection case is before the Court on cross-motions for summary judgment. Defendant James Watson filed a Motion for Partial Summary Judgment and Alternative Motion to Dismiss [Doc. # 18] ("Defendant's Motion"), to which Plaintiff United States of America filed a Response in opposition ("Plaintiffs Response") [Doc. # 20]. Plaintiff United States of America, Internal Revenue Service ("IRS"), filed...
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