is deemed to be a “voluntary gift.” Till, 87 Ill.App.2d at 361; 231 N.E.2d at 643. Second, at the time of the transfer, Gamble was in default on loans from the Indiana National Bank and knew of legal proceedings being brought against him to .reduce that claim to judgment. Gamble was also aware no later than May 16, 1977 that the IRS was auditing him for his 1975 taxes. Although those taxes had not yet been assessed, the law is well settled, for fraudulent conveyance purposes, tax liabilities are due and owing on the date the returns are required to be filed and not the date of assessment. United States v. St. Mary, 334 F.Supp. 799, 803 (E.D.Pa.1971); United States v. van der Horst, 270 F.Supp. 365, 368 (D.Del.1967). See also Zeddies v. United States, 357 F.2d 897, 899 (7th Cir.1966) (<HOLDING>). Therefore, the second element of constructive
holding that debtor could not avoid a judicial lien where after accounting for unavoidable liens and mortgages he had no equity in the property and therefore no interest on which to avoid the judicial lien holding that a spouse was bound by a conveyance of community property to which she was not a party because of her knowledge and acquiescence to the conveyance holding that statutory liens under 26 usc  6322 by contrast arise at time of assessment and that government was therefore relegated to its rights as a creditor to avoid a preassessment conveyance holding that the chapter 13 trustee had standing to avoid liens as impairing exemptions to prevent inequitable distribution of payments caused by debtors failure to avoid lien as impairing exemption holding that the phrase return of income used in 26 usc  6012 is synonymous with the phrase return of tax used in 26 usc  6151