OPINION
MILTON POLLACK, Senior District Judge.
By this action, the United States seeks to reduce to judgment a ten million dollar civil penalty assessed against the defendant by the Department of the Treasury pursuant to former 31 U.S.C. § 1103. That section, now codified at 31 U.S.C. § 5321(a)(2), authorizes the Secretary of the Treasury to impose a civil penalty on a person not filing a report, or filing a report containing a material omission...
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