MEMORANDUM & ORDER
GORTON, District Judge.
In this action to recover on federal tax liens, the plaintiff, the United States of America ("the government"), has moved for partial summary judgment and for entry of a final and separate judgment pursuant to Fed.R.Civ.P. 54(b).
I. Background
In a complaint filed on July 27, 2006, the government alleges that defendants Philip and Ninfa Beninati ("the Beninatis") failed...
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