MEMORANDUM AND ORDER
ROSENTHAL, District Judge.
Plaintiff, the United States, on behalf of the Internal Revenue Service ("IRS"), has sued defendants, Dennis C. and Bernice M. Gates, to reduce to judgment unpaid federal income taxes owed for tax years 1980, 1981, 1988, and 1991. The government has moved for summary judgment on its claim. (Docket Entry No. 13). Defendants have responded, (Docket Entry No...
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