MEMORANDUM OPINION
TILLEY, District Judge.
This case comes to this Court on appeal from the Bankruptcy Court. The Plaintiffs appeal Bankruptcy Judge Stocks' April 28, 1995 order (Adversary Proceeding Number 93-2087) in which he ordered that the United States' motion to dismiss Count II of Plaintiffs' complaint be granted, that the United States' motion for summary judgment on Count III of Plaintiffs' complaint be granted, and that Plaintiffs' motion for...
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