ORDER
BRITT, District Judge.
Before the court is the Internal Revenue Service's ("IRS") appeal from the decision of the bankruptcy court granting the joint motion of appellee Sandra E. Diperna and the Chapter 13 trustee to avoid federal tax liens. For the reasons discussed below, the decision of the bankruptcy court is REVERSED.
I. FACTS
Appellee filed a Chapter 13 bankruptcy petition on 27 October 1994. Thereafter, the IRS...
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