OPINION AND ORDER
KEVIN THOMAS DUFFY, District Judge.
The United States of America (hereinafter "United States"), Chemical Bank New York Trust Company (hereinafter "Chemical Bank"), Benedict Ginsberg (hereinafter "Ginsberg" and the Sociedad Anonima de Inversiones Comerciales e Industriales (hereinafter "SAICI") have each moved for summary judgment in this tax proceeding.
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