MEMORANDUM OPINION AND ORDER SUBORDINATING TAX PENALTY CLAIMS
ROBERT A. MARK, Bankruptcy Judge.
Cassis Bistro, Inc., the debtor in this Chapter 11 case (the "Debtor"), seeks to subordinate nonpecuniary tax penalty claims for purposes of distribution under its confirmed liquidating plan. For the reasons that follow, the Court finds that the nonpecuniary tax penalty claims in this case can and should be subordinated to other allowed unsecured claims...
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