MEMORANDUM OPINION AND ORDER
T. JOHN WARD, District Judge.
Pending before the Court are Defendant Kenneth O. Goolsby's ("Goolsby") Motion for Summary Judgment (Dkt. No. 62) and the United States' Cross Motion for Summary Judgment (Dkt. No. 66). In their competing motions, Goolsby and the United States ask the Court to determine the priority of the United States' federal tax lien and Goolsby's judgment lien with respect to property owned by Defendants...
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