OPINION AND ORDER
JUDITH C. McCARTHY, United States Magistrate Judge.
Plaintiff the United States of America ("Plaintiff") commenced this action on December 20, 2021, pursuant to 26 U.S.C. § 7401, seeking a judgment for unpaid tax penalties levied on Defendant Philip Colasuonno ("Defendant") under 26 U.S.C. § 6682. (Docket No...
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