OPINION
RYAN, Circuit Judge.
We must decide in this appeal whether the lower courts erred in using a "prudent investor rate" to calculate a claim in a bankruptcy proceeding involving unfunded benefit liabilities for a defined benefit pension plan (DBPP) under the Employee Retirement Income Security Act of 1974 (ERISA). We must also determine whether a claim for missed minimum funding contributions is entitled to a "tax" priority under 11 U.S.C. § 507...
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