MEMORANDUM AND ORDER
BELOT, District Judge.
This matter comes before the Court on cross-motions for summary judgment pursuant to Federal Rule of Civil Procedure 56 (Docs. 31 & 38).
I. STATEMENT OF THE CASE
This is an action by Gerald E. Kane ("Kane") against Capital Guardian Trust Company ("CGTC") for conversion and breach of fiduciary duty. Kane had failed to pay his 1989 income taxes, resulting in a statutory federal tax lien...
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