MEMORANDUM AND ORDER
HEARTFIELD, Chief Judge.
Before the Court is the Plaintiff's Amended Motion for Summary Judgment (doc. # 66) and the United States' Cross Motion for Partial Summary Judgment (doc. # 73). After careful consideration of the motions and the applicable law, the Court is ready to make its ruling.
BACKGROUND
Plaintiff brought this lawsuit against the United States to quash two federal tax liens and to quiet title to...
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