OPINION
DAVID E. NIMS, Jr., Bankruptcy Judge.
On August 25, 1986, the Debtor, Reef Petroleum Corporation (Reef), and the Official Unsecured Creditors' Committee (the Committee), brought this adversary proceeding against the United States through the Internal Revenue Service (IRS) to recover a tax refund allegedly owed Reef in the amount of $112,613.57. The alleged claim arose as follows. The IRS mistakenly paid the same refund twice. The IRS discovered the...
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