MEMORANDUM OPINION
H. FRANKLIN WATERS, District Judge.
This case is before the court on the plaintiff's motion for partial summary judgment on count one of the complaint and the motion for summary judgment on counts one and two of the complaint filed by defendants, Jack Jepsen, Kris Jepsen, and Karen Jepsen Makutenas. In count one, the United States seeks to foreclose a federal tax lien. In count two, the United States seeks to set aside as a fraudulent...
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