MEMORANDUM
MOTZ, Chief Judge.
The State of Maryland, Montgomery County and Baltimore County have instituted this action against The Antonelli Creditors' Liquidating Trust (the "Liquidating Trust") and three entities to which the Liquidating Trust transferred parcels of real property. Plaintiffs seek a money judgment for unpaid State and County real estate transfer and recordation taxes. Two questions are presented: (1) whether plaintiffs are prohibited from...
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