MEMORANDUM OPINION AND ORDER
ROVNER, District Judge.
I. INTRODUCTION
On January 25, 1988, Judge Schwartz of the United States Bankruptcy Court for the Northern District of Illinois, Eastern Division, ("Bankruptcy Court") issued a Memorandum Opinion and Order holding that the Internal Revenue Service ("IRS") was not entitled to post-petition interest on its pre-petition oversecured tax claim against the estate of Vincent and Barbara LaPiana ("Debtors...
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