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IN RE KULZER ROOFING, INC.

Bankruptcy No. 90-11525S.

139 B.R. 132 (1992)

In re KULZER ROOFING, INC., Debtor.

United States Bankruptcy Court, E.D. Pennsylvania.

April 10, 1992.

Attorney(s) appearing for the Case

Kenneth E. Carobus, Morris, Adelman & Dickman, Philadelphia, Pa., trustee.

Sanford G. Rosenthal, Sagot, Jennings & Sigmond, Philadelphia, Pa., for Unions.

Rawle & Henderson, Philadelphia, Pa., for Debtor.

Frederic Baker, Asst. U.S. Trustee, Philadelphia, Pa.

OPINION

DAVID A. SCHOLL, Bankruptcy Judge.

A. INTRODUCTION

In Begier v. Internal Revenue Service, 496 U.S. 53, 110 S.Ct. 2258, 110 L.Ed.2d 46 (1990), the Supreme Court held that 26 U.S.C. § 7501(a) of the Internal Revenue Code ("the IRC"), when aided by legislative history expressing such an intention, 110 S.Ct. at 2265-67, provides that any voluntary payments of "trust-fund taxes" by a debtor allow the...

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