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IN RE WHITE

No. 06-1462.

487 F.3d 199 (2007)

In re Charles A. WHITE, Jr.; Anita D. White, Debtors. Internal Revenue Service, Creditor-Appellee, v. Charles A. White, Jr.; Anita D. White, Debtors-Appellants, and John F. Logan, Chapter 13 Trustee, Trustee.

United States Court of Appeals, Fourth Circuit.

Decided: April 23, 2007.

As Amended June 7, 2007.

Attorney(s) appearing for the Case

ARGUED: Joseph A. Bledsoe, III, Raleigh, North Carolina, for Appellants. Karen Grace Gregory, United States Department of Justice, Tax Division, Washington, DC, for Appellee. ON BRIEF: John T. Orcutt, Raleigh, North Carolina, for Appellants. George E.B. Holding, United States Attorney, Office of the United States Attorney, Raleigh, North Carolina; Eileen J. O'Connor, Assistant Attorney General, Robert W. Metzler, United States Department of Justice, Tax Division, Washington, DC, for Appellee.

Before WILLIAMS, MICHAEL, and SHEDD, Circuit Judges.

Affirmed by published opinion. Judge WILLIAMS wrote the opinion, in which Judge MICHAEL and Judge SHEDD joined.

OPINION

WILLIAMS, Circuit Judge.

Charles A. White and Anita D. White ("the Whites") appeal from the district court's reversal of the bankruptcy court's order granting their bankruptcy petition and confirming their plan of reorganization under Chapter 13 of the Bankruptcy Code. As part of their plan of reorganization, the Whites proposed...

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