OPINION
SAROKIN, District Judge.
This matter is before the court on motion of plaintiff United States for partial summary judgment against defendants Dr. James Mazzara and his wife, Ruth Mazzara.
Dr. James Mazzara, a surgeon, is a chronically delinquent taxpayer. His unpaid assessments from 1968 through 1978 are alleged to be in excess of $165,000.
Because Dr. Mazzara's tax obligations were seriously in arrears, the government, in 1973, forced...
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