MEMORANDUM
GILES, District Judge.
Appellee, H & H Beverage Distributors, Inc., filed a voluntary petition under Chapter 11 of the Bankruptcy Code on January 20, 1984, and was granted debtor-in-possession status. In August of 1984, Appellant, Department of Revenue of the Commonwealth of Pennsylvania, conducted a sales tax audit of Appellee for the years 1981-1984. Appellant then sent Appellee a "Notice of Audit Assessment." (Record of Appeal, Exhibit...
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