District Court, N.D. Illinois September 30, 2015, Case No. 14 C 5072 (Illinois Department of Revenue v. Elk Grove Village Petroleum, LLC)

MEMORANDUM OPINION AND ORDER

John Robert Blakey, United States District Judge

In this bankruptcy appeal, this Court must decide whether the Bankruptcy Court erred when it decided that Appellant Illinois Department of Revenue’s *674(“IDOR”) “interest” in the Debtors’ property was without value and thus not entitled to “adequate protection” under Section 363(e) of the Bankruptcy Code.