MEMORANDUM OPINION
SPENCER, District Judge.
In this action, plaintiff Bay Savings Bank, F.S.B. ("Bay Savings"), seeks, inter alia, an Order declaring void the sale of certain real property seized by defendant Internal Revenue Service ("IRS") in connection with the collection of federal income tax liabilities of defendant Ellis D. Corbett, and/or an Order declaring that Corbett redeemed such property.
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