MEMORANDUM OPINION
ERWIN I. KATZ, Bankruptcy Judge.
This matter comes before the Court on the Objection of S.N.A. Nut Company ("Debtor") to the Priority Tax Status of Claim # 128, filed by the California Walnut Commission ("Commission"), under § 507(a)(8) of the Bankruptcy Code ("Code"). The Commission was established by the California Legislature in 1987,
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