MEMORANDUM AND ORDER
SHABAZ, District Judge.
Appellant United States of America brings this appeal from the final order of the Bankruptcy Court voiding appellant's tax lien. Jurisdiction is based upon 28 U.S.C. § 158(a). The parties agree that no issues of fact are presented by this appeal and, therefore, the Court conducts a de novo review.
BACKGROUND
Appellant holds a perfected tax lien for a claim of approximately $41,000...
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