MEMORANDUM AND ORDER
SEYBERT, District Judge.
Pending before the Court are cross-motions for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure in this action commenced by the United States of America (hereinafter the "Government" or "Plaintiff"), pursuant to Title 26 United States Code, Sections 7401 and 7403, seeking to have this Court declare the conveyance of certain real property to Defendant Mary Ellen Margaret Mazzeo...
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