CYNTHIA HOLCOMB HALL, Circuit Judge:
I
Ronald C. Gibson owned and operated Gibson Construction Company as a sole proprietorship during tax years 1977 through 1981. During those years he failed to pay certain taxes. His total unpaid tax liability, including interest, amounted to $69,161.55. The government filed notices of federal tax liens on two pieces of property in which Gibson had an interest at the time. After unsuccessful attempts at collection, the...
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