MEMORANDUM OPINION
THOMAS E. JOHNSTON, District Judge.
Pending before the Court is the United States' Motion for Summary Judgment [Docket 34]. This matter is before the Court on the United States' Complaint for Federal Taxes [Docket 1], wherein the United States seeks to recover unpaid taxes from Dr. Francis J. Whelan by foreclosing on a parcel of real property in Wyoming County, West Virginia. The action originally named as defendants Dr. Whelan, his three...
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