MEMORANDUM OPINION
GRADY, District Judge.
The dispute which forms the basis of this bankruptcy appeal arose when the Internal Revenue Service ("IRS") attempted to collect employment withholding taxes from certain individual corporate officers of Rayson Sports, Inc. ("appellee"), a corporation which filed for bankruptcy under Chapter 11. Pursuant to the Internal Revenue Code ("the Code"), 26 U.S.C. § 1 et...
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