No. 75-1411.

530 F.2d 781 (1976)

UNITED STATES of America, Appellant, v. Edward J. AHRENS, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided February 17, 1976.

Attorney(s) appearing for the Case

Robert T. Duffy, Atty., Tax Div., Dept. of Justice, Washington, D.C., for appellant.

Robert E. Johnson, U.S. Atty., Sam Hugh Park, Asst. U.S. Atty., Ft. Smith, Ark., Scott P. Crampton, Asst. Atty. Gen., and Gilbert E. Andrews and Leonard J. Henzke, Jr., Washington, D.C., appeared on brief.

R. L. Wommack, Fayetteville, Ark., for appellee.

Before ROSS, STEPHENSON and WEBSTER, Circuit Judges.

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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