ORDER RULING ON MOTION FOR SUMMARY JUDGMENT
JOHNSON, District Judge.
The plaintiff, Samco Mortg. Co., commenced this action in state court as one for foreclosure of its real estate mortgage encumbering property on which the IRS has filed several tax liens. The action was removed to this court on February 13, 1989. The IRS has moved for summary judgment seeking a declaration that its liens have priority over the mortgage held by the plaintiff.
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