OPINION OF THE COURT
D. BROOKS SMITH, District Judge.
The government appeals an order of the United States District Court for the District of New Jersey affirming a bankruptcy court order denying the government statutory penalties for appellee American Biomaterials Corporation's (American's) failure to file timely tax returns and pay federal taxes duly owed. The bankruptcy court had jurisdiction of this matter under 28 U.S.C. § 157(b); the district...
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