OPINION
MARILYN MORGAN, Bankruptcy Judge.
The court is asked to determine the validity of the State Board of Equalization's (SBE) claim against the debtor, Renovizors, Inc. (Renovizors). The SBE filed a proof of claim for $442,194.18, which includes $230,846.11 in underreported sales taxes, $57,711.71 in fraud penalties, and $130,551.75 in interest. Renovizors objects to the claim, contending that the SBE's audit methodology is incorrect and that the fraud...
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