MEMORANDUM OPINION
MACKENZIE, District Judge.
This is an action by the United States seeking to reduce to judgment unpaid wagering tax liabilities, interest and fraud penalties assessed against the defendant-taxpayer, Harry L. Donovan. The defendant asserts that he is not liable for the tax on the ground that the assessments were made without any rational basis, and for the fraud penalty on the ground that his guilty plea to a charge of violating Section...
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