(b) or (c), whatever the division is determined to be between Angelos and the United States, it will have nought remaining of the $54,646.34 of which it can avail itself. This will probably be true notwithstanding the result of the additional factual determination regarding the amount of the tax lien. That determination becomes necessary because the original tax liens filed on February 13,1975 for the tax periods ending December 31, 1971 and 1972 were withdrawn or discharged on December 10,1976. On August 29, 1975 they were refiled with accumulated interest, along with additional liens for the tax periods ending December 31, 1973 and 1974. None of these liens were presented evidentiarily to the court; however, it is apparent from the colloquys between court and counsel in the record (<HOLDING>) that both court and counsel were aware of
holding that the court had jurisdiction despite a remand to the bankruptcy court for entry of an order allocating the amount and extent of tax liens recognizing the substantial body of case law discussing distinction between preliminary and postliminary activities on the one hand and principle activities of employment on the other recognizing the liens on the one hand and representing that the tax claim had been released on the other holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens recognizing a traditional distinction between the public and governmental acts of sovereign states on the one hand and their private and commercial acts on the other