MEMORANDUM-OPINION
G. WILLIAM BROWN, Bankruptcy Judge.
This matter comes before the Court on motion for summary judgment by the defendant, United States of America, and on cross motion for summary judgment by the plaintiff, Sherwin Williams Company, both claiming lien priority to accounts receivable of the Dave Thomas Company, Inc. ("debtor") due from Whittenberg Engineering & Construction Company ("Whittenberg"). The plaintiff filed this adversary proceeding...
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