MEMORANDUM
TAURO, District Judge.
Background
Thomas F. and Frances Zoppo had four sons: Robert, James, Joseph, and Thomas A. On August 23, 1990, Mr. and Mrs. Zoppo named Joseph as trustee of the Zoppo Family Trust, a newly created entity for the benefit of Thomas A., who is disabled. On the same day, they also created the Realty Trust, a Massachusetts nominee trust, to hold title to their property...
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