ORDER GRANTING PARTIAL SUMMARY JUDGMENT
COLLIER, District Judge.
Plaintiff (the Government) brought this action to recover unpaid income taxes for the tax years 1975, 1976, 1977, 1978, 1979, and 1980. The Government seeks to set aside allegedly fraudulent transfers of real and personal property; to foreclose federal tax liens on the fraudulently transferred property; and to obtain judgment for any tax liability not satisfied by the foreclosure. The...
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