MEMORANDUM
ROBERT F. KELLY, District Judge.
The United States brings this action to reduce to judgment federal tax assessments made against Richard Lommel Atkinson Gallagher ("Gallagher") and to set aside as fraudulent a conveyance of property from Gallagher to his parents, Richard and Sally Gallagher. The United States has moved for Summary Judgment. For the reasons that follow, that motion will be granted in part and denied in part.
I....
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