MEMORANDUM
RALPH H. KELLEY, Bankruptcy Judge.
The bankruptcy trustee for W.L. Jackson Company (Jackson) brought this action against the Internal Revenue Service (IRS) to recover a tax refund. In early October, 1981, Jackson filed a petition in bankruptcy for reorganization under chapter 11 of the Bankruptcy Code. The case continued as a reorganization until March, 1983, when it was converted to a liquidation case under chapter 7 of the Bankruptcy Code. The...
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