OPINION AND ORDER
ACOSTA, District Judge.
The present case is an appeal pursuant to 28 U.S.C. § 1334 from several Bankruptcy Court orders holding that debtor/appellee, Hospital San Carlos ("San Carlos"), could use certain payments made to the Puerto Rico Department of Labor to set off certain post bankruptcy petition taxes owed to creditor/appellant, the United States Internal Revenue Service ("the IRS").
The general issues on appeal are whether...
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