pellants must show that "the issue is difficult and of first impression and involves more than just a strong disagreement among the parties." In re T.R. Acquisition Corp., No. M47, 1997 U.S. Dist. LEXIS 1186, 1997 WL 51500, at *2 (S.D.N.Y. Feb. 6, 1997)., The district court should genuinely doubt the bankruptcy court'