MEMORANDUM
DAVIS, District Judge.
This is an appeal by the United States from an adverse summary judgment entered by the bankruptcy court. Specifically, the bankruptcy court held that appellee, the chapter 7 trustee, was entitled to recover from the government, as avoidable "fraudulent conveyances," payments by the debtor to the Internal Revenue Service ("IRS") out of debtor's funds, to cover the tax liability of...
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