The following excerpt is from In re Fill, 82 BR 200 (Bankr. S.D.N.Y. 1987):
Brown v. Felsen, 442 U.S. 127, 132, 99 S.Ct. 2205, 2210, 60 L.Ed.2d 767 (1979) (emphasis added). We have made that careful inquiry and find several factors which militate against application of the doctrine.
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