MEMORANDUM OF DECISION
JIM D. PAPPAS, Bankruptcy Judge.
Before the Court for disposition is a motion filed by the Internal Revenue Service (hereafter "IRS") for relief from the automatic stay. IRS seeks permission to set off Debtor's federal income tax refunds attributable to tax years 1989, 1990 and 1991 against her liability for income taxes for tax year 1987. The Chapter 7 Trustee objects to the motion. The relevant facts are stipulated.
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