PER CURIAM:
Morris Cooper-Smith appeals from an order of the Eastern District of New York, Bartels, J., granting summary judgment in favor of the government in its action to reduce to judgment income tax and civil fraud penalty assessments for the years 1945, 1946 and 1947. Judge Bartels denied Cooper-Smith's cross-motion for summary judgment which asserted that the statute of limitations barred the government's action, and judgment was entered for $86,495.52.
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