MEMORANDUM AND ORDER
EDGAR, District Judge.
This matter is presently before the Court upon the appeal of the United States of America from the bankruptcy court's determination, by an order and memorandum opinion dated September 1, 1988, that the amended proof of claim of the United States for internal revenue taxes (Claim 26d) should be disallowed, thereby sustaining the debtors' objection. In re Miller,
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