MEMORANDUM OPINION
DAVID V. O'BRIEN, District Judge.
The issue presented in this appeal is whether the Government of the Virgin Islands may reopen a debtor's plan for reorganization 26 months after the plan was confirmed. We hold that the Government's claim for pre-petition taxes is barred by laches and affirm the bankruptcy court's refusal to reopen the case. We also affirm the court's reaffirmation of its earlier order that the debtor pay its post-petition...
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