MEMORANDUM AND ORDER
MORAN, Senior District Judge.
On December 22, 1998, the government filed two complaints pursuant to Internal Revenue Code ("IRC") § 7405 to recover tax refunds issued to the Inland Steel Industries Pension Trust (Inland Trust) (98 C 8217) and the Caterpillar Tractor Company Master Trust (Caterpillar Master Trust) (98 C 7272). The Northern Trust Company (Northern Trust)...
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