OPINION
NOVALYN L. WINFIELD, Bankruptcy Judge.
The issue presently before the Court is whether the reimbursement claim filed by the New Jersey Department of Labor ("NJDL" or the "Department") against the debtor, United Healthcare System, Inc., ("United" or the "Debtor") should be afforded priority of payment as either an administrative expense claim pursuant to 11 U.S.C. §§ 503(b)(1)(B) and 507(a)(1), or a priority tax claim pursuant to 11 U.S...
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