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IN RE DEER PARK, INC.

No. 92-15802.

10 F.3d 1478 (1993)

In re DEER PARK, INC., aka Deer Park Ski Area, Debtor, UNITED STATES INTERNAL REVENUE SERVICE, Appellant, v. CREDITORS COMMITTEE; Deer Park, Inc., Appellees.

United States Court of Appeals, Ninth Circuit.

Decided December 6, 1993.

Attorney(s) appearing for the Case

Gary D. Gray and James A. Bruton, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellant.

Gerald F. Ellersdorfer, San Francisco, CA, for appellees.

Before: FERGUSON, THOMPSON and O'SCANNLAIN, Circuit Judges.

DAVID R. THOMPSON, Circuit Judge:

This is an appeal from the Bankruptcy Appellate Panel's ("BAP") decision in United States v. Deer Park, Inc. (In re Deer Park, Inc.), 136 B.R. 815 (9th Cir. BAP1992). The BAP affirmed an allocation order of the bankruptcy court which required the Internal Revenue Service ("IRS") to credit payments, made to it in a liquidating plan of reorganization under...

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