In Re Spendthrift Farm, Inc., Debtor. Spendthrift Farm, Inc. v. United States

RYAN, Circuit Judge.

Plaintiff, Spendthrift Farm, Inc., appeals the district court’s order reversing a bankruptcy court decision which sustained objections to statutory interest for past taxes arising under I.R.S. § 6601(d)(1). This ap peal addresses whether the district court correctly found that the closing agreement between the IRS and the plaintiff did not preclude the IRS from assessing restricted interest. For the following reasons, we affirm.

I

This ease arises from the IRS’ proof of claim in the Chapter 11 Bankruptcy proceedings of Spendthrift for taxes and interest assessed against…