MEMORANDUM AND ORDER
WEXLER, District Judge.
This is an appeal from an order of the bankruptcy court (J. Hall), which granted Suffolk County priority over secured creditors with respect to pre-petition real property taxes and denied the County priority with respect to its claim for post-petition real property taxes, interest, and penalties.
I. BACKGROUND
On October 17, 1977, the debtor, Parr Meadows Racing Association ("Parr Meadows") filed...
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