MEMORANDUM OPINION
MERRITT S. DEITZ, Jr., Bankruptcy Judge.
In this case of competing prepetition tax liens, state and federal, we are urged to assign the higher priority to the lien which arose first in point of time. Under the clear language of the Bankruptcy Code we are unable to reach that result.
State and federal tax liens in excess of $100,000 were asserted against the property of John Darnell before he took bankruptcy, with the federal tax...
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