MEMORANDUM OPINION
FLAUM, District Judge:
This matter comes before the court on the appeal of GNB, Inc. (GNB) from an order of the Bankruptcy Court allowing the Trustee of Palmer Trading Company (Palmer Trading) to retain GNB's federal income tax refund. For the reasons stated below, that order is reversed.
The Bankrupt, Palmer Trading, initially filed its petition under Chapter 11 of the Bankruptcy Code, 11 U.S.C. §§ 1101-74, but the matter...
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