ORDER
DEVITT, District Judge.
In this quiet title action, the plaintiff questions the validity of nominee liens filed against some of its property by the United States pursuant to I.R.C. § 6321. The government has contended that taxpayers John A. and Angela Ellering, husband and wife, fraudulently transferred property to plaintiff, a Minnesota business trust, in order to avoid paying their income tax liability.
On March 21, 1986, this court...
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