MEMORANDUM OPINION AND ORDER
L. EDWARD FRIEND, II, Bankruptcy Judge.
This matter is before the Court pursuant to the Complaint to Determine Priority of Liens filed by the debtors, Harry K. McCord and Linda Susan McCord ("the McCords"). Defendant United States Department of Treasury, Internal Revenue Service ("IRS") and Defendant Petland, Inc. ("Petland") both claim a priority security interest in the same leasehold items, equipment, and inventory. The Court...
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