MEMORANDUM OPINION
JOHN T. LANEY, III, Bankruptcy Judge.
On April 10, 1989, a hearing was held on Debtor's Objection to Claim No. 11 and Debtor's Motion for Rule 9011 sanctions against the United States of America by and through the Internal Revenue Service (hereinafter "IRS"). The court invited both parties to submit briefs on the issue of whether Rule 9011 sanctions were appropriate. At the end of the briefing schedule, both parties presented oral argument...
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