ORDER
LEGGE, District Judge.
This matter came before the court on the appeal by the United States of America from the Bankruptcy Judge's Order of April 23, 1986. The oral argument was heard on September 26, 1986, and the court considered the record, the arguments of counsel, and the applicable authorities.
I
On April 15, 1981, Richard J. Morrell filed a petition for bankruptcy under Chapter 11 of the Bankruptcy Code. Four claims were filed...
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