ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
McAULIFFE, District Judge.
This interpleader action involves a lien priority dispute between the Internal Revenue Service ("IRS") and Carrabassett Investment Corp. ("Carrabassett"). Carrabassett and the IRS each have liquidated claims against Abigail D. Kimball ("Kimball"). Each seeks to reach and apply her beneficial interest in the Berger Trust, administered by First N.H. Bank
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