MEMORANDUM OF DECISION
JAMES H. WILLIAMS, Chief Judge.
Before the court are briefs filed by the United States in each of the above adversary proceedings, on behalf of its agency the Internal Revenue Service (IRS), supporting its claimed interest in certain proceeds of a state court partition sale. The First National Bank of Shelby (FNB), one of the defendants, filed a response to each brief which essentially supports the IRS' position but also argues that...
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