On February 12, 1979, Edward W.W. Howell, d/b/a Howell Electric Company ("Howell"), filed a petition for reorganization under Chapter 11 of the Bankruptcy Act, 11 U.S.C. § 1101 et seq. On June 22, 1979, the California State Board of Equalization ("Board") filed a priority claim in the proceeding for sales and use tax. The bankruptcy court disallowed the Board's claim, ruling that the California...
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