PER CURIAM:
In this appeal, Baldwin County Savings & Loan Association ("BCSL") appeals the district court's grant of summary judgment in favor of the Internal Revenue Service ("IRS"). The dispute involves two conflicting interests in a parcel of real property in Baldwin County, Alabama: the foreclosure interest of the mortgagor, BCSL, and a tax lien held by the IRS. BCSL foreclosed on the property and sold it at a nonjudicial auction to satisfy the mortgagee's...
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