OPINION
QUIST, District Judge.
Plaintiff United States of America ("Government") filed this action against Defendants Blake W. Valleau, Joan Valleau, and Jean M. Valleau, pursuant to 26 U.S.C. §§ 7401, 7403, to reduce to judgment penalty assessments against both Blake and Joan Valleau, to set aside an allegedly fraudulent conveyance by Blake and Joan Valleau to Jean M. Valleau, and to foreclose its federal tax liens on the same conveyed...
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