MEMORANDUM OPINION
TILLEY, District Judge.
This opinion consolidates two bankruptcy appeals brought by appellants Wilbur and Ruth Hollar. In civil case number 2:93CV00714, the Hollars appeal the Bankruptcy Court's order in their Chapter 13 bankruptcy proceeding (Bankr. Case No. 93-11389) allowing the Internal Revenue Service's secured and priority claims against the bankruptcy estate. In the second case, civil...
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