MEMORANDUM OPINION AND ORDER
BOYLE, United States Magistrate Judge.
This tax collection case concerns tax assessments for income earned by defendant Roger David Elton ("Elton" or "defendant") during tax years 1988, 1989, 1990, and 1991. The relevant facts, as set forth in the complaint, the parties' Rule 56.1 Statements, and other documents submitted in connection with defendant's motion for summary judgment and the government's cross-motion for summary...
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