BATTISTI, Chief Judge.
This is an appeal in a diversity action brought by the plaintiff-appellee, The Lincoln Savings Bank (Lincoln), a New York corporation, against the defendants-appellants, J. William Hayes and twenty-eight (28) other California residents (the fee owners). At issue is the nonpayment of property taxes on real estate located in Leitchfield, Grayson County, Kentucky. For the reasons stated below, we reverse the judgment of the district court.
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