MEMORANDUM
KATZ, District Judge.
The United States seeks to reduce federal personal income tax assessments for the years 1983, 1984, and 1985 to judgment and to foreclose federal tax liens on property which the defendant taxpayer, Marie Carson, deeded to her daughter, defendant Raeann Carson Rapucci. For the reasons which follow the United States' motion for partial summary judgment is granted.
I. Taxes Owed
Mrs. Carson admits that...
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