SAM, District Judge.
Defendant Bobby G. Gosnell appeals from an order of the district court holding him liable for unpaid federal personal income taxes, penalties and interest for the years 1976 through 1982, and ordering that the government's tax liens against Gosnell's real property be foreclosed.
The government commenced this action pursuant to 26 U.S.C. § 7403 seeking to reduce Gosnell's unpaid tax liabilities to judgment, to set aside as fraudulent...
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