MEMORANDUM AND ORDER
BECKWITH, District Judge.
Background
This matter is before the Court on the appeal by the Internal Revenue Service ("IRS") of Judge William Clark's order of September 29, 1989, in the bankruptcy case of Paul Tipps, Case No. 3-83-00919. In this order, Judge Clark disallowed the claims of the IRS with respect to the Ru-El Company ("Ru-El") and the Ellison Coal Company ("Ellison"), finding that the debtor was not a responsible...
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