ORDER
WILLIAM J. O'NEILL, Bankruptcy Judge.
In the within case the United States of America, Department of the Treasury, Internal Revenue Service (IRS) filed a supplemental claim for $281,614.45 to which the Debtor, The Overly-Hautz Company (OHC) has objected. The parties submitted the matter on stipulations, oral argument and briefs.
The parties agreed to the following stipulation of facts:
"1. This Court has subject matter jurisdiction...
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