OPINION
BROWN, District Judge.
This matter comes before the Court upon the appeal of the Internal Revenue Service from the Order of the United States Bankruptcy Court for the District of New Jersey ("Bankruptcy Court") issued by the Honorable William H. Gindin, U.S.B.J., March 17, 2000. This Court exercises appellate jurisdiction pursuant to 28 U.S.C. § 158(a). The Court having considered the submissions of the parties and having heard oral argument...
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