MEMORANDUM AND ORDER
COHN, District Judge.
I. Introduction
A.
This is a chapter 7 bankruptcy appeal. 28 U.S.C. § 158. George P. Dakmak, the bankruptcy trustee in this proceeding (the trustee), commenced an adversary proceeding against the United States Internal Revenue Service (IRS) to recover a preferential payment made by the debtors to the IRS. The bankruptcy court found that the payment was not a preference. In a Memorandum and...
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