MEMORANDUM—DECISION & ORDER
MCAVOY, Chief Judge.
Plaintiff United States of America ("plaintiff") commenced an action against defendants pursuant to 26 U.S.C. §§ 7401 and 7403 to reduce tax assessments to judgment against Sheldon Hansel and to set aside certain alleged fraudulent conveyances of stock to Defendants Christy, Grant, Shelley, and Hope Hansel.
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