OPINION
PANNER, Chief Judge.
The United States issued tax levies against Loren and Helen Griffith, purchasers of the Ramble Inn Cafe. A wrongful levy action filed by Julie Ray, defendant in the present action, was dismissed. Subsequently, the United States filed this action seeking: (1) to reduce to judgment tax liabilities of Lloyd Larson, Julie Ray's father; (2) to set aside as fraudulent Lloyd Larson's transfer of the Ramble Inn Cafe to his children;...
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