MEMORANDUM OPINION
BRIAN BARNETT DUFF, District Judge.
The IRS wants Emil and Judith Stavriotis' money. Lots of it. The bankruptcy court (the Stavriotis' have filed for Chapter 11 protection) said the IRS asked for too much, too late. The IRS has turned to this court, hoping for a different result. Its hopes are misplaced.
Background
The Stavriotis' filed their Chapter 11 bankruptcy petition...
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