OPINION AND ORDER
BUTLER, District Judge.
This matter is before the court on the appeal of the United States from the orders of the Bankruptcy Court confirming the debtors' chapter 13 plan, sustaining the debtor's objection to its claim for trust fund tax liability under 26 U.S.C. § 6672, and denying its motion for discovery sanctions under Fed.R.Civ.P. 37(d).
Background
On October 11, 1991, debtors David and Debra Dallas filed...
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