MEMORANDUM OF DECISION
MESKILL, Circuit Judge, Sitting by Designation.
The Internal Revenue Service (IRS) brought this action to set aside a conveyance of property between the defendants as fraudulent, to declare valid the IRS' tax liens on said property and to order the foreclosure of the liens. Jurisdiction arises under 28 U.S.C. §§ 1340 and 1345 and 26 U.S.C. §§ 7402 and 7403.
On October 10, 1978 the United States Attorney...
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