MEMORANDUM AND ORDER
SACHS, Chief Judge.
The United States has appealed the Bankruptcy Court's order in the matter of William F. Irvin and Nancy K. Irvin, Bankruptcy No. 82-02594-3, Adversary No. 88-0686-3 (Bkrtcy.W.D.Mo.), in which it was denied the ability to collect post-petition penalties and interest on non-dischargeable tax debts from the debtors' after-acquired property. The bankruptcy petition in this case was filed by the debtors on August 12, 1982...
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