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IN RE JOHNSON REHABILITATION NURSING HOME, INC.

Bankruptcy No. 92 B 22116. Adversary No. 98 A 01429.

239 B.R. 168 (1999)

In re JOHNSON REHABILITATION NURSING HOME, INC., Debtor. Sheldon L. Solow, Trustee, Plaintiff, v. United States of America, Defendant.

United States Bankruptcy Court, N.D. Illinois, Eastern Division.

April 1, 1999.

Attorney(s) appearing for the Case

Bradley S. Schmarak, Tracy L. Treger, Sachnoff & Weaver, Chicago, IL, for Plaintiff.

Stacy Hallett, Tax Division, U.S. Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OPINION ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

JACK B. SCHMETTERER, Bankruptcy Judge.

Sheldon L. Solow, Trustee in the related bankruptcy case filed under Chapter 7 of the Bankruptcy Code, 11 U.S.C. § 101 et seq. ("Code"), has brought this Adversary proceeding seeking equitable subordination of the late-filed priority claim of the United States Internal Revenue Service ("IRS"). The Adversary issues are before this Court on the...

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