In Re Moore

MEMORANDUM AND ORDER

BILL H. BRISTER, Bankruptcy Judge.

Internal Revenue Service (“IRS”) objects to the plan filed by Clarence Arol Moore, debtor, which provides for payment of pre-petition priority tax liability of $17,109.18 in six equal annual installments of $2,851.73 each. The plan provides for no interest 1 to be paid to IRS on the deferred installments. IRS opposes confirmation of the plan whereby its debt would be paid in deferred installments unless interest on the deferred cash payments is incorporated at the rate provided by § 6621 of the Internal Revenue Code. The following summary…