MEMORANDUM
CAFFREY, Senior District Judge.
This case is an appeal from an adversary proceeding in the United States Bankruptcy Court. In 1987, the Creditor's Committee and Trustees of Beverages International ("Creditor's Committee") initiated an adversary proceeding against the Commonwealth of Massachusetts Department of Revenue ("Commonwealth") contesting the Commonwealth's priority claims for unpaid alcohol excise taxes owed by Beverages International...
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