BERTELSMAN, District Judge:
Order
The matter is before the court on the defendant's motion for summary judgment.
On 9/10/75, the U.S. Tax Court entered decisions determining an income tax liability against defendant of $180,981.92 plus interest for 1949 through 1961. On 12/30/77, the U.S. brought this action in this court to reduce the federal income tax assessment against defendant to judgment, to set aside a conveyance of stock as being a fraud...
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