OPINION
SWEET, District Judge.
This is an appeal by the Internal Revenue Service ("IRS") from a decision of the United States Bankruptcy Court for the Southern District of New York disallowing the IRS's claim against the trustee ("Trustee") of Sapphire Steamship Lines, Inc. ("Sapphire") for penalties and interest for the non-payment of estimated corporate income taxes. The decision of the Bankruptcy Court is reversed, and the IRS's claim for $21,572.05 for...
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