MEMORANDUM
MOTZ, District Judge.
This is an action brought by the United States to foreclose liens for federal estate taxes in the amount of $1,366,430 due on the estate of Lorraine D. Hebb ("Lorraine"). Pending before me is a motion for summary judgment filed by the government.
The question presented is whether certain real property known as Walnut Grove Farm was owned by Lorraine at the time of her death or whether, approximately five months prior...
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