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IN RE SPENDTHRIFT FARM, INC.

No. 90-6063.

931 F.2d 405 (1991)

In re SPENDTHRIFT FARM, INC., Debtor. SPENDTHRIFT FARM, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 1, 1991.

Attorney(s) appearing for the Case

Joseph H. Terry, Barbara B. Edelman (argued), and James A. Nitsche, Wyatt, Tarrant & Combs, Lexington, Ky., for plaintiff-appellant.

Louis DeFalaise, U.S. Atty., David Middleton, Asst. U.S. Atty., Office of the U.S. Atty., Lexington, Ky., Lawrence P. Blaskopf, U.S. Dept. of Justice, Tax Div., Gary R. Allen, Acting Chief, Richard Farber, Murray S. Horwitz, and Teresa McLaughlin (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for defendant-appellee.

Before RYAN and SUHRHEINRICH, Circuit Judges, and McRAE, Senior District Judge.

RYAN, Circuit Judge.

Plaintiff, Spendthrift Farm, Inc., appeals the district court's order reversing a bankruptcy court decision which sustained objections to statutory interest for past taxes arising under I.R.S. § 6601(d)(1). This appeal addresses whether the district court correctly found that the closing agreement between the IRS and the plaintiff did not preclude the IRS from assessing restricted interest. For the...

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