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IN RE UAL CORP.

No. 02 B 48191.

336 B.R. 370 (2006)

In re UAL CORPORATION, et al., Debtors.

United States Bankruptcy Court, N.D. Illinois, Eastern Division.

January 3, 2006.

Attorney(s) appearing for the Case

James H.M. Sprayregen, Todd F. Maynes, Marc Kieselstein, David R. Seligman, Erik W. Chalut, James J. Mazza, Jr., Kirkland & Ellis LLP, Chicago, IL, for United Air Lines, Inc.

Patrick J. Fitzgerald, Henry J. Riordan, Washington, DC, for United States of America, Department of the Treasury, Internal Revenue Service.

MEMORANDUM OF DECISION

EUGENE R. WEDOFF, Bankruptcy Judge.

These Chapter 11 cases are before the court on the debtors' motion for a determination of tax liability under § 505(a) of the Bankruptcy Code (Title 11, U.S.C.). The debtors seek a ruling that property to be distributed under their proposed Chapter 11 plan is not "wages" subject to federal taxes. The Internal Revenue Service has opposed the motion, not only on its merits, but also on the ground...

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