United States v. Thomassen

RICHARD E. ROBINSON, Senior District Judge.

I. INTRODUCTION

The United States of America brings this action under 26 U.S.C. Sections 7401-7403, 28 U.S.C. Sections 1340 and 1345 to reduce certain tax liabilities to judgment, to set aside an allegedly fraudulent conveyance of real property, and to foreclose federal tax liens against such property. Jurisdiction of this Court is proper pursuant to 28 U.S.C. Section 1396 and the above-mentioned provisions. This Memorandum constitutes the Court’s findings of facts and conclusions of law in accordance with Fed. R.Civ.P. 52(a).

This case was tried to…