MEMORANDUM OPINION AND ORDER
BABCOCK, District Judge.
Appellants, Debtors Edson Pamittan Mallo and Liana Carol Mallo, appeal an order of the United States Bankruptcy Court for the District of Colorado dated January 3, 2013, denying their Motion for Summary Judgment and granting the Motion for Summary Judgment filed by the Appellee, The United States of America. [Appellate Record Doc # 6-1 pg. 197] Oral argument would not materially assist me in the determination...
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