OPINION
DAVID E. NIMS, Jr., Bankruptcy Judge.
David P. Sweeney, sole shareholder of American Plastics Corporation and Foret Plastics Corporation (collectively "the Debtors"), filed this adversary proceeding on November 2, 1980, to determine the validity of a lien on accounts receivable held by Walter E. Heller & Company (Heller). On February 26, 1982, the United States of America (the IRS) was allowed to intervene as a party plaintiff, and on March ...
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