MEMORANDUM & ORDER
NATHANIEL M. GORTON, District Judge.
In this action to recover federal tax liens, the plaintiff, the United States of America ("the government"), has moved for summary judgment.
I. Background
In a complaint filed on July 27, 2006, the government alleges that defendants Philip and Ninfa Beninati ("the Beninatis") failed to pay their joint federal income taxes for the 1985, 1986 and 1988 tax...
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