OPINION
QUIST, District Judge.
This action involves an appeal from the bankruptcy court. The Debtor, Holly's, Inc. (Holly's), is requesting a reversal of the bankruptcy court's order granting the City of Kentwood's ("Kentwood") motion for summary judgment. The bankruptcy court held that "it had subject matter jurisdiction to render a final judgment on the Debtor's real property tax liability to Kentwood for the years 1989 through 1992 only, . . ....
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