MEMORANDUM OPINION AND ORDER
JOSEPH C. ELLIOTT, Bankruptcy Judge.
The Plaintiff, a debtor corporation, brought this action to enjoin the Internal Revenue Service from collecting from one of its officers, directors and part-owners personally a 100% tax penalty for unpaid pre-petition federal withholding and employment taxes. The Court granted a Temporary Restraining Order to prohibit the Internal Revenue Service from selling the homestead of the director...
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