MEMORANDUM OPINION
THOMAS M. BRAHNEY, III, Bankruptcy Judge.
This matter came before the court on a Motion to Dismiss Adversary Proceeding or Alternatively for Adequate Protection filed by the Department of Justice ("DOJ") on behalf of the Internal Revenue Service ("IRS"). The Debtors, Jerry and Nedrey Creel, filed an Opposition to the Motion to Dismiss. The underlying adversary proceeding was initiated when Hancock Bank ("Hancock") filed an Adversary...
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