MEMORANDUM AND ORDER
WEXLER, District Judge.
This is an appeal from a decision of the Bankruptcy Court (Holland, J.) holding that certain proofs of claim filed by the Internal Revenue Service ("IRS") were late claims that were properly subordinated to claims of general creditors. According to IRS, the claims at issue were amendments to earlier claims and the Bankruptcy Court incorrectly held the claims to be untimely. For the reasons that follow, this Court...
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