IN RE PAN

Civil Action No. 96-11201-PBS.

209 B.R. 152 (1997)

In re George S. PAN, Debtor. UNITED STATES of America, Appellant, v. Joseph BRAUNSTEIN, Trustee, Appellee.

United States District Court, D. Massachusetts.

March 5, 1997.


Attorney(s) appearing for the Case

Susan M. Poswistillo, U.S. Attorney's Office, Boston, MA, Henry J. Riordan, U.S. Department of Justice, Tax Division, Washington, DC, for appellant.

Alan L. Braunstein, Riemer & Braunstein, Boston, MA, for appellee.


MEMORANDUM AND ORDER

SARIS, District Judge.

I. Introduction

In this appeal pursuant to 28 U.S.C. § 158(a), the United States of America challenges a bankruptcy court's decision to disallow a proof of claim filed by the Internal Revenue Service ("IRS"). During the Chapter 7 proceeding, the bankruptcy court rejected the government's argument that the proof of claim for a federal tax penalty in the amount of $123,371.49 was itself prima facie...

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