MEMORANDUM AND ORDER
LUNGSTRUM, District Judge.
This case comes before the Court on appeal from an order of the United States Bankruptcy Court dated August 27, 1990. In that order, the Bankruptcy Court sustained the Debtor's request to file a proof of claim on behalf of the Internal Revenue Service out of time. The Bankruptcy Court further ordered that the proof of claim filed on behalf of the IRS would be treated as a tardily filed claim under 11 U.S.C...
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