MEMORANDUM OPINION
MARTIN V.B. BOSTETTER, Jr., Chief Judge.
The issue here arises upon an objection by Dominion Investments, Inc. ("DII"), plan administrator for Manchester Lakes Associates, to a proof of claim for prepetition tax penalties filed by the County of Fairfax, Virginia ("the County").
On December 7, 1984, an involuntary petition for relief was filed against Manchester Lakes Associates under Chapter 11 of the United States Bankruptcy Code...
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