MEMORANDUM
MOORE, District Judge.
Plaintiff Chase Manhattan Bank ("Chase" or "plaintiff") moves for summary judgment. Defendant Virgin Islands Bureau of Internal Revenue ("VIBIR" or "defendant") opposes plaintiff's motion and moves for summary judgment on its crossmotion. For the reasons set forth below, this Court will grant plaintiff's motion for summary judgment and deny defendant's cross-motion for summary judgment.
I. BACKGROUND
Between...
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