MEMORANDUM OPINION
SAMUEL J. STEINER, Bankruptcy Judge.
This matter is before the Court on the motion of the United States for reconsideration of the Court's ruling that Master-Halco's claim to interpleaded funds is superior to that of the government.
The facts are undisputed. On December 3, 1990, the IRS assessed the debtors with income taxes of $59,763.30 for 1989. On April 27, 1991, Master-Halco obtained a $92,714.92 judgment against the debtors...
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