MEMORANDUM
BENSON EVERETT LEGG, Chief Judge.
This is a civil action in which the United States seeks to reduce to judgment federal tax assessments against Robert M. Hoyt and to void allegedly fraudulent transfers of property and money from Mr. Hoyt to his wife, Sandra S. Hoyt. Specifically, the United States alleges in Count I of the Amended Complaint that Mr. Hoyt owes $417,836.17 in unpaid tax assessments. In Counts II through IV of the Amended...
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