MEMORANDUM OPINION AND ORDER
FRANK, District Judge.
INTRODUCTION
This case came before the Court on January 12, 2007, pursuant to Plaintiff United States of America's (the "Government") Motion for Summary Judgment against Defendants Nash Sonibare and Liberty Financial Group, Inc. (collectively, the "Defendants"). In its Complaint, the Government requests injunctive relief under 26 U.S.C. §§ 7407, 7408, for violations of 26 U.S.C. §...
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