MEMORANDUM OPINION
SPORKIN, District Judge.
This is a dispute as to the priority of competing interests in a debtor's assets. This court must decide whether the Internal Revenue Service ("IRS") or a private creditor, Security Finance Group, Inc., is entitled to the proceeds due debtor CMA, Inc. ("CMA") from a suit over a contract between CMA and Centex Construction Co., Inc. ("Centex"). This contract was the subject of litigation which has since been settled...
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