MEMORANDUM OPINION AND ORDER
KANE, District Judge.
This is an appeal by the government from an order of the bankruptcy court avoiding three liens of the Internal Revenue Service filed against a parcel of property in Routt County, Colorado. Before October 22, 1979, the debtor owned the Routt County property. On that date he conveyed all of his interest in the property to his wife, Sandra Smythe. On January 3, April 10, and May 22, 1980, the IRS recorded notices...
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