MEMORANDUM OPINION
BARNES, District Judge.
This proceeding is a tax refund action filed by the Trustee in this Chapter 11 bankruptcy case. The Trustee and the United States have each appealed the findings of the bankruptcy court, and it is before the district court for a third time. Oral arguments were heard on June 20, 1995, and the following is the Court's review of the bankruptcy decision and judgment pursuant to Fed.R.Bankr.P. 8013.
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