MEMORANDUM AND ORDER
ROGERS, District Judge.
This is an appeal from the bankruptcy court. The United States contends that the bankruptcy court erred (1) in finding that payments under a covenant not to compete were not property of the debtor's estate and (2) in finding that a payment made by the debtor to the Internal Revenue Service was voluntary and that the IRS is equitably estopped from applying this payment to the debtor's income tax liability...
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