EUGENE A. WRIGHT, Circuit Judge:
In this case we must decide whether a property owner, holding title pursuant to a forclosure sale under a second deed of trust, can obtain redemption reimbursement for preredemption payments to a senior lienor. We reverse the district court's conclusion that the property owner is collaterally estopped from seeking reimbursement. But we affirm its conclusion that the property owner failed to comply with valid Treasury Regulations in...
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