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UNITED STATES v. BIELASKI

No. 149, Sept. Term, 1999.

756 A.2d 583 (2000)

360 Md. 67

UNITED STATES v. Carla BIELASKI, as Personal Representative of the Estate of Daniel Shay, et al.

Court of Appeals of Maryland.

July 26, 2000.

Attorney(s) appearing for the Case

Stuart M. Fischbein (Kenneth L. Greene and Bridget M. Rowan, Dept. of Justice, on brief), Washington, DC., of Counsel: Lynn Ann Battaglia, U.S. Atty., for appellant.

No argument on behalf of appellees.

Argued before BELL, C.J., and ELDRIDGE, RODOWSKY, RAKER, WILNER, CATHELL and HARRELL, JJ.

BELL, Chief Judge.

At issue in this case are the competing claims of the United States and six general creditors of the Estate of Daniel Shay. The claim of the United States is pursuant to 26 U.S.C. § 66721 of the Internal Revenue Code and represents mostly a penalty assessed against the deceased for unpaid employment taxes of Shay Heating and Air Conditioning Company, Inc. ("Shay Heating...

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