OPINION
SWEET, District Judge.
The United States of America (the "Government") appeals from an order by the Bankruptcy Court (the "Order") denying the Government's motion to setoff an obligation owed to the appellee Whimsy, Inc. (the "Debtor") by the United States Department of the Treasury, United States Customs Service ("Customs"), against a debt owed by the Debtor to the United States Department of the Treasury, Internal Revenue Service (the "IRS...
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