MEMORANDUM OPINION
ROBERT F. FUSSELL, Bankruptcy Judge.
I. Background
On December 6, 1990, the debtors filed their petition under Chapter 13 of the Bankruptcy Code. On February 12, 1991, the Internal Revenue Service (IRS) filed a $177,562.99 proof of claim for unpaid taxes, interest, and penalties for the 1981, 1982, 1983, 1984, and 1986 tax years.
On April 11, 1991, the debtors filed an objection to the...
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