Opinion
No. 89-35673.
Argued and Submitted June 8, 1990.
Decided July 12, 1990.
Gary R. Allen, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant-appellant.
Allan Galbraith, Carlson Drewelow, Wenatchee, Wash., for plaintiff-appellee.
Appeal from the United States District Court for the Eastern District of Washington; Justin L. Quackenbush, District Judge, Presiding.
Before WRIGHT, WALLACE and KOZINSKI, Circuit Judges.
We consider whether the IRS must timely file a proof of its unsecured claims in order to obtain priority status in a Chapter 13 bankruptcy. We conclude that it must, adopting as our own the excellent opinion of Judge Quackenbush below, reported at 102 B.R. 790 (E.D.Wash. 1989).
AFFIRMED.