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IN RE ABEL

Civil A. No. 94-7199.

200 B.R. 816 (1996)

In re Paul E. ABEL, Debtor. Paul E. ABEL, Appellant, v. UNITED STATES of America, Appellee.

United States District Court, E.D. Pennsylvania.

September 3, 1996.

Attorney(s) appearing for the Case

Michael P. Forbes, Norristown, PA, for Paul E. Abel.

Edward Sparkman, Chapter 13 Trustee, Philadelphia, PA, pro se.

Frederic Baker, Assistant U.S. Trustee, Philadelphia, PA, pro se.

MEMORANDUM

DuBOIS, District Judge.

This case is before the Court on an appeal from a January 5, 1994 bankruptcy court order allowing a proof of claim by the Internal Revenue Service ("IRS") against the estate of the Appellant, Paul Abel ("debtor"), for unpaid federal withholding taxes.1 For the reasons discussed below, the bankruptcy court's order will be reversed.

I. BACKGROUND

This case arises...

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