ROSS, Circuit Judge.
This suit was brought by the United States against Edward Ahrens to reduce certain unpaid tax assessments to judgment. The amount of unpaid taxes claimed by the government was $152,151.55 plus interest, for the calendar year 1961. After discovery, the government moved for summary judgment and the taxpayer moved for judgment on the pleadings. The district court denied the government's motion for summary judgment, and granted summary judgment to...
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