MEMORANDUM AND ORDER
ELFVIN, District Judge.
This is an appeal from an order of the Bankruptcy Court which would require the Internal Revenue Service ("the IRS") to turn over to the debtor property which the IRS had levied upon and seized. My Order filed May 6, 1981 stayed the effect of the Bankruptcy Court's order pending disposition of this appeal. For the reasons set out below, I am reversing that court's order.
The debtor, Whiting Pools, Inc...
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