MEMORANDUM OF DECISION
DAVID N. NAUGLE, Bankruptcy Judge.
INTRODUCTION
Viking Ranches, Inc. ("Viking Ranches") filed a petition under Chapter 11 of the Bankruptcy Code, 11 U.S.C. § 101 et seq., on March 10, 1988. Two months later, S. David and Debora Plummer ("Plummers" or "Debtors") also filed for Chapter 11 protection. The Internal Revenue Service ("IRS") filed this action against the Plummers to determine the amount of its...
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