MEMORANDUM OPINION AND ORDER
HELEN S. BALICK, Bankruptcy Judge.
The Manager of Revenue for the City and County of Denver (Denver or Manager) has brought this motion for payment of an administrative expense claim for unpaid use tax, penalties and interest. 11 U.S.C. §§ 503(a), (b)(1)(B)(i) and (C). Continental Airlines, Inc. opposes payment of the administrative claim on the grounds that Continental is...
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