Plaintiff - Appellant:
THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION, f/k/a The Bank of New York Trust Company, N.A., as Successor to JP Morgan Chase Bank N.A. as Trustee for Ramp 2006RP4
Defendant - Appellee:
INTERNAL REVENUE SERVICE, Department of the United States Treasury
STEPHEN S. PHIPPS, BRADLEY J. HERRELL, MELANIE CUMMINGS, as Trustee
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