PER CURIAM:
We adopt the well-reasoned and thorough opinion of the district court in this case. The opinion of the district court is annexed hereto.
AFFIRMED.
APPENDIX
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA DUBLIN DIVISION
In re: Costas J. GUST, Debtor.
v.
United States of America, acting by and through...
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