In re Baker

ORDER

HOGAN, District Judge.

This is a bankruptcy appeal challenging Bankruptcy Judge Higdon’s November 30, 1993 order overruling the debtors’ objection to the claim of the Internal Revenue Service (IRS). In late 1978 or early 1979, the debtors hired an attorney, Maxwell Berg, who specialized in tax planning. Mr. Berg developed a tax shelter investment plan which required his clients to invest in sham master recording limited partnerships. He then filed fraudulent returns for his clients, including the debtors, and obtained refunds for previous tax years. The IRS learned of the fraudulent…