MEMORANDUM OPINION & ORDER
JOAN B. GOTTSCHALL, District Judge.
The government brought this federal tax lien foreclosure case against Robert B. Horsting, Sr. and Margaret M. Horsting (collectively, the "Horsting parents") stemming from assessments for several years between 1978 and 1987. On September 8, 1997, judgment was entered in favor of the government and against the Horsting parents with respect to income tax liabilities from the above-described...
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