MEMORANDUM OPINION
HAROLD C. ABRAMSON, Bankruptcy Judge.
This dispute arises in the context of Placid Oil Company's ("Placid's") Objection to Administrative Claim Filed by the Internal Revenue Service ("Objection"). Appearing on behalf of Placid were Khent Rowton and Richard Bruse of the law firm of Simon, Anisman, Doby, Wilson & Skillern. The Department of Revenue (referred to herein as the "Government" and the "IRS") was represented by Grover Hartt...
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