OPINION
EAST, Senior District Judge:
The Bankruptcy Judge held that the tax claim of the United States (Government) against the members of a bankrupt partnership was subordinated by 11 U.S.C. § 23(g) to the claims of individual creditors of the individual Bankrupts. The District Court reversed, deciding that the Government was an individual creditor and its tax claim held priority under 11 U.S.C. § 104...
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