ORDER
W. HOMER DRAKE, Jr., Bankruptcy Judge.
Currently before the Court in this matter is the Motion for Partial Summary Judgment filed by the United States of America. The Motion comes as part of an adversary proceeding, filed by Gregory D. Bishop (hereinafter "the Debtor") to avoid tax liens to the extent they exceed the value of the property involved. The United States, by contrast, seeks a determination that the Debtor's 1991 federal tax liabilities...
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