OPINION
DUNN, Bankruptcy Judge.
The appellant, the United States, on behalf of its agency, the Internal Revenue Service ("IRS"), appeals several orders entered by the bankruptcy court in connection with a summary judgment motion by the appellee, Diana K. Carey, the chapter 11 trustee (the "trustee").
This appeal arises out of a dispute between the IRS and the trustee as to whether the IRS may assert its right to set...
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