Madan v. US BY AND THROUGH IRS

MEMORANDUM-DECISION AND ORDER

McAVOY, Chief Judge.

The plaintiffs John Madan and the National Bank of Olyphant have brought the instant action against the United States of America, the defendant, to quiet title on a certain piece of land situated in Broome County, New York. Presently before the court are two motions for summary judgment made by the plaintiffs and the defendant.

I. BACKGROUND

On or about April 8, 1993, a foreclosure sale was held on the steps of the Courthouse in Binghamton, New York. During this foreclosure sale, plaintiff National Bank of Olyphant (“Olyphant”) purchased a real…