MEMORANDUM OPINION
JUDITH A. BOULDEN, Bankruptcy Judge.
PROCEDURAL BACKGROUND
A petition for relief under Chapter 11 of the Bankruptcy Code was filed by Mack J. and Dorothy Bowen (Bowens) on the 29th day of August, 1986. The United States Internal Revenue Service (I.R.S.) filed an amended proof of claim in the case in the amount of $78,225.59.
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