MEMORANDUM OPINION
TIMOTHY J. MAHONEY, Bankruptcy Judge.
A hearing on confirmation of C.R. Druse, Sr., Ltd.'s, ("debtor") Chapter 12 plan was heard on September 25, 1987. Appearing on behalf of debtor was William Biggs; the Internal Revenue Service ("IRS") was represented by Steve Russell and Loren Mark. Following the hearing, all parties were requested to submit briefs addressing the legal issues raised at the hearing.
Statement of Facts
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