MEMORANDUM OPINION
MASSIE M. TILLMAN, Bankruptcy Judge.
On the 10th day of February, 1997, the Court considered the Motions to Convert filed by Darr Equipment, Inc. ("Darr") and the Internal Revenue Service ("IRS"). This Court has jurisdiction and venue is proper pursuant to 28 U.S.C. §§ 1334 and 1408. Furthermore, this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A). This memorandum opinion shall serve as findings
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