MEMORANDUM
GEORGE C. PAINE, II, Chief Judge.
I. Introduction
This matter is before the Court on the United States Customs Service's ("Customs") objection to a proposed Agreed Order between the Chapter 11 Trustee and the Internal Revenue Service ("IRS") which compromised and settled the IRS's claims, including the treatment of a tax refund owed by the IRS to the estate. Customs asserts a right to setoff against the IRS tax refund for prepetition...
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