MEMORANDUM DECISION
ROBERT D. MARTIN, Bankruptcy Judge.
The United States Department of Agriculture ("USDA") seeks relief from stay to set off a debt the Internal Revenue Service ("IRS") owes a Chapter 7 debtor for a tax refund against a debt the debtor owes it on a home loan guaranty. No one disputes that both are agencies for the United States and that they are considered a single entity for analysis of setoff. The IRS owes the debtor a tax refund for...
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