OPINION
RICHARD MILLS, District Judge.
Pending before the Court is the motion for summary judgment filed by Defendant, The Windsor Organization, Inc.
I. INTRODUCTION
This action is brought pursuant to 28 U.S.C. §§ 1340 & 1345 and 26 U.S.C. §§ 7401 & 7403. Plaintiff United States of America seeks to foreclose upon commercial real property located at 709 (also known as 719) West Jefferson, Springfield, Sangamon...
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