MEMORANDUM OPINION
JERRY A. BROWN, Bankruptcy Judge.
This proceeding comes before the court on the complaint of Compass Marine Services, Inc. ("Compass") seeking a judgment ordering the United States of America, Department of the Treasury, Internal Revenue Service ("United States" or "IRS") to reallocate tax payments to the trust fund portion of taxes paid by Compass. The parties agreed to submit the case for a decision on stipulated facts and briefs...
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