In Re Sapphire Steamship Lines, Inc., Debtor. Internal Revenue Service v. Trustee, Sapphire Steamship Lines, Inc.

TIMBERS, Circuit Judge:

The trustee (“appellant”) of Sapphire Steamship Lines, Inc. (“debtor”) appeals from a final judgment entered November 15, 1984 in the Southern District of New York, Robert W. Sweet, District Judge, 1 reversing an order of the bankruptcy court, Burton R. Lifland, Bankruptcy Judge, 2 and allowing the claim of the Internal Revenue Service (“IRS” or “appellee”) against appellant for penalties in the amount of $21,572.05 for the tax years 1978, 1979, 1981, and 1982 because of appellant’s failure to pay estimated corporate income taxes on a quarterly basis. On appeal,…