MEMORANDUM AND ORDER ON PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
SKINNER, Senior District Judge.
This is an action for the refund of amounts paid in satisfaction of a transferee assessment made against the plaintiff pursuant to 26 U.S.C. § 6901. Plaintiff alleges that he is not liable as a transferee under § 6901 because the transfers were made without the intention to defraud, hinder or delay the collection of past taxes and fines due the...
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