Paradis

MEMORANDUM OF DECISION

JAMES B. HAINES, JR., Chief Judge.

At issue is confirmation of the debtors’ chapter 13 plan, the vitality of which hinges on their objection to the claim of the Internal Revenue Service. Both confirmation and the claim objection have been submitted for decision on a stipulated record.1 As discussed below, the objection is sustained, and the plan is confirmed.

Background

The parties agree that the IRS is entitled to a secured claim in the amount of $30,439.07.2 The dispute centers on whether the unsecured balance of the IRS claim is entitled to priority under §§ 507(a)(8)…