ORDER
WARE, District Judge.
The United States appeals a decision of the U.S. Bankruptcy Court discharging an estate from tax liability under 11 U.S.C. § 505(b). The United States contends that, contrary to the bankruptcy court's ruling, the estate is not a "successor to the debtor" as defined in § 505(b). For the reasons set forth below, the decision must be reversed. An estate is not included as a discharged party under § 505(b).
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