MEMORANDUM DECISION
JAMES H. THOMPSON, Bankruptcy Judge.
This matter is before the Court on the objection of debtors, Joseph & Valeria Brady, to the claim of the Internal Revenue Service (IRS). The IRS filed a secured claim for a 100 percent penalty of $47,250.34, which is the unpaid employee withholding taxes for American Electronics Sales, Inc. (American), for the third and fourth quarters of 1982 and the first quarter of 1983. The IRS asserts this...
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