MEMORANDUM OPINION
STEPHEN S. MITCHELL, Bankruptcy Judge.
Before the court are cross-motions for summary judgment filed by the debtors and by the United States of America, one of the two defendants in this adversary proceeding. A hearing was held in open court on May 2, 2000. The debtors and the United States were present by counsel. Oak Cluster Community Council ("Oak Cluster") did not file a response to the motion for summary judgment and was not present...
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