MEMORANDUM OPINION AND ORDER
ST. EVE, District Judge.
Plaintiff United States of America ("United States" or the "Government") sued Defendants Jane Harris and Peter Swan (collectively "Swan") seeking to secure Thomas and Joen Townes' (the "Townes" or "Taxpayers") federal income tax liability by foreclosing federal tax liens pertaining to real property located in Libertyville, Illinois. The Court held a bench trial on November 15, 2005.
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