ORDER GRANTING IN PART AND DENYING IN PART THE GOVERNMENT'S MOTION FOR SUMMARY JUDGMENT
GONZALEZ, District Judge.
Presently before the court is defendant-counterclaimant the United States of America's (the "government") motion for summary judgment pursuant to Federal Rule of Civil Procedure 56. For the reasons stated herein, the Court grants the motion in part and denies it in part.
BACKGROUND
This case arises out of a series of tax penalties...
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