MEMORANDUM
JOAN N. FEENEY, Bankruptcy Judge.
I. INTRODUCTION
The matter before the Court is the Motion of Successor Trustee to Determine Priority of Interest Asserted by the Internal Revenue Service (the "Motion") and the Request of the Internal Revenue Service ("IRS") for Payment of Taxes as an Administrative Expense. The issue presented is whether the IRS is entitled to an administrative expense claim under 11
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