BOWNES, Senior Circuit Judge.
The primary issue in this bankruptcy appeal is whether the Internal Revenue Service (IRS) should be allowed to recover post-petition interest on a tax claim secured by duly perfected liens. This is a rare case for three reasons. One, it is a bankruptcy case where the debtor became solvent during the course of the bankruptcy proceedings. Two, the appeal of the IRS from the judgment of the district court affirming the decision of the bankruptcy...
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