ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
PAUL B. LINDSEY, Bankruptcy Judge.
BACKGROUND
This adversary proceeding was brought by American Bank and Trust Company ("ABT"), in order to resolve a dispute between ABT and Internal Revenue Service ("IRS") over the priority of certain liens on the inventory and accounts receivable of Debtor.
On February 22, 1991, Debtor filed a voluntary petition under Chapter 11 of the Bankruptcy Code...
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