MEMORANDUM DECISION ON APPEAL
KANE, Senior District Judge.
I. Introduction
The government appeals an order of the bankruptcy court which held that the debtor's rights in an ERISA qualified pension plan were superior to the government's. The court below, in a contested proceeding, held that the funds were exempt under federal law and initially ordered the trustee to pay them to the debtor. Upon reconsideration, the bankruptcy court determined...
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