MEMORANDUM
KEITH M. LUNDIN, Bankruptcy Judge.
The issue is whether the State of Tennessee may set off amounts owed to the debtor for prepetition services provided by the debtor to one department of State government against prepetition taxes owed by the debtor to another department of state government. Setoff is appropriate.
I.
In August, 1989, the State of Tennessee contracted with the debtor through its Department of General Services,...
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