OPINION
STEPHEN J. COVEY, Bankruptcy Judge.
On February 28, 1989, a hearing was held upon the confirmation of the Plan of Reorganization ("Plan") submitted by World Wide Inns, Inc. ("World Wide Inns"). Essentially the Plan provides for a liquidation with the payment in full of all claims due the Internal Revenue Service ("IRS") out of the proceeds of the sale of the Debtor's property. The IRS objected to the confirmation of the Plan on the grounds that it...
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