MEMORANDUM AND ORDER In this civil action by the United States (the “Government”) seeking various forms of relief related to unpaid tax liabilities, Defendant Shaindy Lax (“Shaindy”) moves to dismiss all claims asserted against her pursuant to Federal Rule of Civil Procedure 12(b)(6). (See ECF No. 96).1 For the reasons that follow, the motion is denied. BACKGROUND The following facts are alleged in the amended complaint (Am. Compl., ECF No. 106) and are viewed in the light most favorable to the Government. Familiarity with the extensive factual allegations contained in the amended complaint is presumed, and they are recited here only insofar as necessary to dispose of the pending motion. Chaim Lax (“Chaim”) was a diamond merchant and real estate developer who, through numerous business entities, owned parcels of real estate throughout Brooklyn, New York. (See id. 27). In or around November 2006, he was diagnosed with stomach cancer. (See id. 31). He died on or around November 3, 2008. (See id. 35). The executors of his estate (the “Estate”) are his son, Moshe Lax (“Moshe”), and his daughter, Zlaty Schwartz (“Zlaty”). (See id. 37). In addition, Moshe and Zlaty are the trustees of the Lax Family Trust (the “Trust”), an irrevocable trust Chaim had established in 2003, of which Chaim’s children (including Moshe and Zlaty) and grandchildren are beneficiaries. (See id.
61-62). Shaindy is Moshe’s wife. (See id. 74). Moshe and Zlaty have been named as Defendants in this action, in addition to Shaindy and numerous other individuals and business entities. Prior to his death, Chaim knew that he was being audited by the Internal Revenue Service (“IRS”) and that he owed substantial income taxes. (See id. 258). He also knew that his Estate would owe substantial estate taxes following his death. (See id.). The Government alleges that, “[k]nowing of his negative health prognosis, and that he owed millions in income taxes and would owe millions more upon his death, Chaim undertook a series of sham transactions designed to shield his assets from collection by the Internal Revenue Service.” (Id. 32). The Government further alleges that Moshe and Zlaty “continued that effort after his death in order to avoid paying the taxes he owed.” (Id.). As of April 25, 2018, the Estate had unpaid federal tax liabilities of over $60 million. (See id. 41). In this action, the Government seeks various forms of relief related to these unpaid tax liabilities. As relevant to the pending motion, the Government asserts that Moshe and Zlaty orchestrated a series of sham transactions to hide the Estate’s assets from the IRS by conveying them to assorted business entities held in Shaindy’s name. The Government describes three such schemes in the amended complaint, denoted as “Scheme 2″, “Scheme 3″, and “Scheme 4″. Scheme 2 was essentially a continuation of an earlier scheme, denoted as “Scheme 1″. The Government alleges that each of these Schemes “was part of a series of transfers…designed…to place Chaim’s assets beyond the reach of his creditors, including the IRS.” (Id.
