MEMORANDUM AND ORDER
BLOCK, Senior District Judge:
Before the Court are the Report and Recommendation ("R & R") of Magistrate Judge Victor V. Pohorelsky and the objections thereto by the defendant, Emil Thompson ("Thompson"). For the reasons described below, the Court rejects Thompson's objections and accepts the R & R in its entirety.
I
On or about September 11, 1995, a delegate of the Secretary of the Treasury assessed...
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