RULING ON MOTION FOR SUMMARY JUDGMENT
JANET BOND ARTERTON, District Judge.
The United States filed this civil action to enforce tax assessments against Barry Trupin. Arguing that Trupin is barred by res judicata from challenging the assessments and that this action was timely filed, the Government now moves for summary judgment on the ground that no material factual issues remain for trial.
I. Facts and Procedural History
As a threshold...
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