MEMORANDUM OPINION
ZIEGLER, District Judge.
This is an appeal from the Bankruptcy Court of the Western District of Pennsylvania. Pursuant to § 522 of the Bankruptcy Code, 11 U.S.C. § 522; the court below avoided certain government liens constituting non-possessory, non-purchase money security interests in the property of the debtors, John and Sindy Flick. The government contends on appeal that § 522 is inapplicable to liens held by the United...
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