MEMORANDUM DECISION AND ORDER
PAUL HYMAN, Jr., Bankruptcy Judge.
Daniel Bakst, the Chapter 7 Trustee of HDI Partners (the "Trustee"), brought this adversary proceeding to determine the extent, priority, and validity of a lien and/or interest in property. The issue before the Court is whether the Internal Revenue Service ("IRS") has a superior interest in funds which were turned over to the Trustee pursuant this Court's Order granting the Trustee's...
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