MEMORANDUM OPINION
WILLIAM F. STONE, Jr., Bankruptcy Judge.
The issue before this Court is whether the claims of the State of Tennessee Commissioner of Revenue ("Commissioner") for corporate sales and use tax for which the Debtor, Freida G. Rainey, is personally liable by application of the State of Tennessee's "responsible person" statute, Tenn.Code Ann. § 67-1-1443, are entitled to administrative expense priority in the Debtor's personal bankruptcy...
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