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IN RE MILLER

BAP No. EC-93-2330-RVRo. Bankruptcy No. 93-20639-A-13.

174 B.R. 791 (1994)

In re Guy MILLER, Debtor. Guy MILLER, Appellant, v. INTERNAL REVENUE SERVICE, United States Trustee, Lawrence Loheit, Chapter 13 Trustee, Appellees.

United States Bankruptcy Appellate Panel of the Ninth Circuit.

Decided December 1, 1994.

Attorney(s) appearing for the Case

Richard Dangler, Sacramento, CA, Curtis W. Berner, San Francisco, CA, for appellant Guy Miller.

Diana P. Nowezki, Washington, DC, Thomas M. Rohall, Sacramento, CA, for appellee I.R.S., U.S.

Before RUSSELL, VOLINN and ROSS, Bankruptcy Judges.

OPINION

RUSSELL, Bankruptcy Judge:

The debtor objected to the Internal Revenue Service ("IRS") claim on the grounds that the statute of limitations had expired and that consents executed between the tax matter partner and the IRS were invalid. In addition, the debtor attempted to set aside a closing agreement based on an alleged misrepresentation by the IRS. The bankruptcy court overruled the objection to the IRS claim. The debtor appeals. We AFFIRM...

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