MEMORANDUM OPINION
FRANK W. KOGER, Bankruptcy Judge.
The only issue unresolved by the parties to these very complex issues of personal holding company taxes, deficiency dividends, negligence penalties, and the priority or standing thereof, is whether the 5% "negligence penalty" assessed by the Internal Revenue Service under 26 U.S.C. § 6653 should be paid pro rata along with other general unsecured claims or whether it should be subordinated as to said...
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