FINDINGS OF FACT AND CONCLUSIONS OF LAW
OWEN M. PANNER, District Judge.
The United States brings this action to reduce to judgment income tax assessments against defendants Daryl J. Kollman (Kollman) and Marta C. Carpenter (Carpenter). The government claims Kollman and Carpenter jointly and severally owe more than $10 million in income taxes, penalties, and statutory additions for the tax years 1996 and 1997.
After the court trial, these are my findings...
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