MEMORANDUM
CAFFREY, Chief Judge.
This is a civil action for recovery of unpaid income taxes, penalties, and interest alleged to be due and owing to the United States from defendants Louise F. and M. Eli Livingstone. The complaint also seeks an order setting aside an allegedly fraudulent transfer of a parcel of real property by defendant Louise F. Livingstone to defendant Maurice Fine, as Trustee of the Continental Investment Trust, and to set aside a subsequent...
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