MEMORANDUM OF DECISION AND ORDER ON OBJECTION OF INTERNAL REVENUE SERVICE TO SUBORDINATION OF PENALTY CLAIM
ALAN H.W. SHIFF, Bankruptcy Judge.
The Internal Revenue Service objects to confirmation of the debtor's chapter 13 plan for the reason that it impermissibly subordinates an IRS penalty.
BACKGROUND
On July 15, 1985, the debtor filed a petition for relief under chapter 13 of the Bankruptcy Code. On January 31, 1986, the IRS filed an amended...
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