OPINION
ASHLAND, Bankruptcy Judge:
The United States appeals a grant of summary judgment in favor of Robert and Mary Isom (debtors) ordering the removal of prepetition tax liens. We reverse.
FACTS
The facts in this case are undisputed. Debtors owed the United States personal income taxes for the years 1974 through 1982, when they filed a Chapter 7 petition in March 1987. The debtors brought an adversary proceeding seeking a determination...
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