MEMORANDUM OPINION
GLEN M. WILLIAMS, Senior District Judge.
This proceeding is before this court on Appellant's, Internal Revenue Service ("IRS"), appeal of the bankruptcy court's Order confirming the Debtor's, Danny Stewart ("Stewart"), Chapter 13 plan. Jurisdiction in this court is pursuant to 28 U.S.C. § 158(a).
FACTS
The Debtor filed a petition in bankruptcy on November 8, 1993 according to Chapter 13 of the bankruptcy code. 11...
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