MEMORANDUM AND ORDER
WERLEIN, District Judge.
Pending is Defendant/Cross-Claimant the United States of America's Motion for Summary Judgment (Document No. 46). After carefully considering the motion, response, reply and the applicable law, the Court concludes that the United States's motion should be granted.
I. Background
This is a tax liability case previously described in the Court's Memorandum and Order entered May 14...
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