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IN RE REITTER CORP.

Civil Nos. CIV. 11-1132(DRD), 11-1529(DRD). Bankruptcy No. 10-07152 ESL.

475 B.R. 314 (2012)

In re REITTER CORPORATION d/b/a Hospital San Gerardo, Debtor(s). Banco Popular De Puerto Rico, Appellant(s), v. United States of America, Appellee(s).

United States District Court, D. Puerto Rico.

March 31, 2012.

Attorney(s) appearing for the Case

Monique J. Diaz-Mayoral , Rafael Perez-Bachs , Jose R. Gonzalez-Irizarry , McConnell Valdes , San Juan, PR, for Appellant.

Andrew C. Strelka , United States Department of Justice, Washington, DC, for Appellee.

Alexis Fuentes-Hernandez , Fuentes Law Offices, San Juan, PR, for Debtor.

OPINION AND ORDER

DANIEL R. DOMINGUEZ, District Judge.

Pending before the Court are two appeals which have been consolidated, as both are intrinsically intertwined. In both cases, appellant Banco Popular de Puerto Rico ("BPPR") challenges the decision of the bankruptcy court finding that the United States of America through its agency the Internal Revenue Service (the "United States" or the "IRS"), "is the senior lien holder over Debtor's [Reitter Corporation...

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