GEORGE C. PRATT, Circuit Judge:
Because of non-payment of income taxes, the Internal Revenue Service acquired a tax lien on Richard and Susan Rosen's condominium in Syosset, New York. Jerome Norton bought the lien on April 2, 1986, for $137,500, and paid for it in three installments throughout that month, as permitted by 26 U.S.C. § 6335(e)(2)(D). The Rosens attempted to redeem their property on September 29, 1986, by tendering to Norton a check in the amount...
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