MEMORANDUM OPINION
KISER, District Judge.
This matter is before me on appeal from the Bankruptcy Court. The United States of America has appealed the Bankruptcy Court's decision that the government's claim of an excise tax under 26 I.R.C. § 4980 is not entitled to priority under § 507(a)(7)(E) of the Bankruptcy Code. Based upon an examination of the Bankruptcy Code, its legislative history and relevant case law, the decision of the Bankruptcy Court...
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