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IN RE MARTIN

Bankruptcy No. SG05-17981. No. 1:09-CV-963.

426 B.R. 720 (2010)

In re Patrick C. MARTIN, Debtor. United States of America, Appellant, v. Brae Asset Fund, L.P. and Patrick J. Martin, Appellees.

United States District Court, W.D. Michigan, Southern Division.

March 9, 2010.

Attorney(s) appearing for the Case

Patrick C. Martin, pro se.

OPINION AND ORDER

ROBERT J. JONKER, District Judge.

The United States of America ("the IRS") appeals from a judgment of the Bankruptcy Court. The Bankruptcy Court rejected on summary judgment the IRS' bid to treat tax assessments related to the debtor's 2000 and 2001 income tax returns as priority claims under 11 U.S.C. § 507(a)(8)(A)(iii).1 If the IRS obtains priority status on the 2000 and 2001 debts, it will receive...

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