MEMORANDUM
JAMES McGIRR KELLY, District Judge.
This case is before the Court on an appeal from a September 19, 1996 bankruptcy court final order adjudicating the objections of Baskin and Sears, P.C. ("debtor") and the Official Unsecured Creditor's Committee to a proof of claim by the Internal Revenue Service ("IRS"). At issue in this appeal is the appropriate burden of proof on a tax deficiency claim in bankruptcy, as well as factual issues related...
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