MEMORANDUM-OPINION
J. WENDELL ROBERTS, Chief Judge.
This matter is currently before the Court on the motion of the United States for summary judgment. The debtors have filed a lengthy brief in opposition to this motion and the Court has reviewed same. Having considered the respective positions of both parties, the Court concludes that the United States' motion for summary judgment must be sustained.
The facts in this case are largely undisputed and...
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