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IN RE DORROUGH, PARKS & CO.

No. 3:94-cv-732. Bankruptcy No. 92-3209. Adv. No. 92-3213.

185 B.R. 46 (1995)

In re DORROUGH, PARKS & COMPANY, Debtor. Ann MOSTOLLER, Trustee, Plaintiff, v. ASPEN MARINE GROUP, Bank of East Tennessee, Union Planters Bank, and The United States of America, Defendants.

United States District Court, E.D. Tennessee, at Knoxville.

June 2, 1995.

Attorney(s) appearing for the Case

Carol C. Priest, U.S. Dept. of Justice, Tax Div., Washington, DC, for U.S.

John A. Lucas, Hunton & Williams, Knoxville, TN, for First American Nat. Bank.

Doris C. Allen, Bernstein, Stair & McAdams, Knoxville, TN, for Union Planters Nat. Bank.

Ann Reilly Mostoller, Trustee, Mostoller and Stulberg, Oak Ridge, TN.

MEMORANDUM OPINION

JARVIS, Chief Judge.

This is an appeal from an order of the Bankruptcy Court. The appeal arises out of an involuntary Chapter 7 case commenced against the debtor, Dorrough, Parks & Company ("Dorrough Parks"), on April 27, 1992. Jurisdiction is based on 28 U.S.C. § 158(a) and is not in dispute. The Bankruptcy Court held that a federal tax lien asserted by the appellant, the Internal Revenue Service ("IRS"), did not take...

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