MEMORANDUM OPINION AND ORDER
ALBRITTON, Chief Judge.
This case is before the court on appeal from the United States Bankruptcy Court for the Middle District of Alabama ("the Bankruptcy Court"). The United States of America ("the Government") appeals the Bankruptcy Court's final judgment of August 1, 1997, in which the Bankruptcy Court concluded that the Internal Revenue Service ("the IRS") improperly setoff the 1995 federal income tax refund of Debtor...
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