OPINION
WARREN W. BENTZ, Bankruptcy Judge.
Background
The facts are not in dispute. The Internal Revenue Service ("IRS") properly filed a tax lien on May 2, 1991 in the office of the Prothonotary of Erie County, against Michael Duawayne Jacobs, Sr. ("Debtor") for the years 1985 and 1986 in the amount of $5,009.45. This Chapter 13 case was filed September 17, 1991. Included in the bankruptcy estate of Debtor is the following property:
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