COOPER, District Judge.
This matter comes before the Court on appeal from the order of the United States Bankruptcy Court for the District of New Jersey ("Bankruptcy Court") dated April 30, 2004 ("4-30-04 Order"), granting summary judgment in favor of appellee, United Trust Bank ("United"). Appellants, the State of New Jersey Division of Taxation ("NJDOT") and the trustee, Daniel E. Straffi ("trustee"), are joined on this appeal by the intervening appellant, New Jersey...
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