WOODROUGH, Circuit Judge.
On May 22, 1958, the United States brought an action in the District Court of North Dakota under section 7403 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 7403, to foreclose tax liens and for the appointment of a receiver of all the properties of the taxpayer, Fay Heasley, that were subject to the tax liens. Assessments for income taxes, fraud penalties and interest against the taxpayer were made by the Commissioner of Internal...
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