OPINION
PERRIS, Bankruptcy Judge:
The debtors objected to the Internal Revenue Service's ("I.R.S.") penalty assessment pursuant to Internal Revenue Code § 6672 on the grounds that the assessment, which occurred during a prior bankruptcy case, violated the automatic stay of 11 U.S.C. § 362 and was, therefore, void. The United States appeals the order granting the objection. We REVERSE.
FACTS
On February 25, 1983 the debtors Russell...
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