MEMORANDUM OPINION
WILLIAM A. HILL, Bankruptcy Judge.
The instant adversary case was commenced by the trustee seeking a determination of the validity and priority of liens claimed by First Bank North Dakota, N.A.Jamestown (Bank) and the Internal Revenue Service of the United States of America (IRS) in $87,144.28 representing proceeds stemming from the sale of real property by Reuben and Iola Scherbenske (Debtors) to purchasers under a contract for deed....
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