OPINION ON MOTION OF IRS CLAIMING SOVEREIGN IMMUNITY
RODNEY R. STEELE, Chief Judge.
Barry and Deborah Sneller (Plaintiffs) filed a petition for relief under the Bankruptcy Code on November 13, 1987. The debtors' plan was confirmed by this court on January 6, 1988. The debtors' confirmed plan provided for full payment as a priority debt of the taxes owed to the Internal Revenue Service (IRS). Debtors received their Chapter 13 discharge on November 13, 1991...
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