LEFKOW, District Judge.
Plaintiff, United States of America ("the United States") filed a two count complaint seeking to set aside a conveyance of real property into a land trust and to foreclose a tax lien against the conveyed property. The Court's jurisdiction rests on 28 U.S.C. §§ 1340 (internal revenue) and 1345 (United States as plaintiff). The United States and defendants Norman and Lilly Paradise cross-moved for summary judgment. Defendant Citibank...
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