MEMORANDUM OPINION
CHARLES R. SIMPSON, III, District Judge.
The Commissioner of Internal Revenue assessed employment taxes against Stewart Mechanical Enterprises, Inc. ("Stewart Mechanical") for various tax periods in 2004, 2005, and 2006. Notices of federal tax liens were filed against Stewart Mechanical in Jefferson County, Kentucky on 7/11/06, 8/24/06, 9/22/06, and 11/24/10. Stewart Mechanical ceased doing business in 2007 and the...
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