FISHER, Circuit Judge:
Cool Fuel appeals the Ninth Circuit Bankruptcy Appellate Panel's ("BAP") decision that a claim for unpaid Use Fuel taxes filed by the California State Board of Equalization ("the Board") in Cool Fuel's bankruptcy proceeding was not barred by the three-year statute of limitations provided in California Revenue and Taxation Code ("R & TC") § 8971. It argues alternatively that if the Board's claim is not barred by § 8971, it is not...
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