OPINION
IRENAS, Senior District Judge.
This is a civil federal tax liability suit brought by the United States against Defendant Ruth Patras pursuant to the Uniform Fraudulent Transfer Act ("UFTA"), N.J.S.A. §§ 25:2-20 to -34. The United States argues that Defendant Patras's husband, Dr. Anthony Patras, sought to evade his federal income tax liabilities by fraudulently
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