MEMORANDUM
O'NEILL, District Judge.
I. Introduction
This is a non-jury action brought by the United States to reduce to judgment certain federal tax assessments made against defendant Thomas W. Purcell for the tax years 1980-1986. The government seeks to set aside as fraudulent the conveyance of real property located at 211 Cricket Avenue, Ardmore, Pennsylvania from defendant Thomas Purcell...
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