MEMORANDUM OF DECISION
DAVID E. RUSSELL, Chief Judge.
The Internal Revenue Service ("the Service") seeks retroactive relief from the automatic stay under 11 U.S.C. § 362(d) in order to validate a tax assessment made in violation of the automatic stay. A hearing was held and the matter was taken under submission. For reasons set forth below, the court will deny the motion.
FACTUAL BACKGROUND
Prior to filing for bankruptcy, Debtors...
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