MEMORANDUM
MORTON, Senior District Judge, Sitting by Designation.
This case is on appeal from an order denying the Government's motion to dismiss an adversary proceeding. The opinion of the Bankruptcy Judge is hereby adopted as the opinion of this court and is made a part hereof as fully as if copied verbatim herein.
An appropriate order will be entered.
ORDER OF BANKRUPTCY COURT
RALPH H. KELLY, Bankruptcy Judge.
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