MEMORANDUM AND ORDER
GEORGE C. SMITH, District Judge.
This is an appeal by the United States of America of the August 21, 1986 Order of the Bankruptcy Court for the Southern District of Ohio which held that the filing of a Chapter 13 petition does not toll the running of the three year period for determining tax claim priority status pursuant to 11 U.S.C. § 507(a)(7)(A)(i).
FACTS
As of April 9, 1986, the debtors, Rudolph S. Molina...
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