In Re ProMedCo of Los Cruces

MEMORANDUM OPINION AND ORDER

DENNIS MICHAEL LYNN, Bankruptcy Judge.

Before the Court 1 is the objection of Debtors (the “Objection”) to claim no. 115 filed by the Internal Revenue Service (“IRS”) in the amount of $3,001,238 (the “Claim”) 2 based on the IRS’s contention that Debtors 3 underpaid their 1997 taxes. Jurisdiction over this core proceeding lies in the bankruptcy court pursuant to 28 U.S.C. §§ 1834 and 157(b)(2)(B). This Memorandum Opinion constitutes the Court’s findings of fact and conclusions of law. See Fed. R. Bankr.P. 7052 and 9014.

I. Background

Debtors were engaged in the…