MEMORANDUM
MOTZ, Chief Judge.
The relevant facts on this bankruptcy appeal may be briefly stated. John Driggs, a debtor in a Chapter 11 proceeding, owed a tax liability to the Internal Revenue Service. The IRS, in turn, owed Driggs a refund for another tax year. During the course of the bankruptcy proceeding Driggs proposed a plan of reorganization to which the IRS did not object and which has now been confirmed. The plan provides that the tax liability...
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