MEMORANDUM OPINION
CHASANOW, District Judge.
In this appeal from the Bankruptcy Court, Murray L. Deutchman, Appellant, challenges the determination that confirmation of his Chapter 13 plan in 1994 did not release or extinguish the IRS lien against his residence upon payment of an amount less than that claimed for back taxes. The Bankruptcy Court found that Cen-Pen Corp. v. Hanson,
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