In Re Century Boat Company, Debtor. Internal Revenue Service v. Century Boat Company, David G. Kipley, Trustee

BOYCE F. MARTIN, Jr., Circuit Judge.

The Internal Revenue Service filed an untimely proof of claim against the bankruptcy estate of Century Boat Company for unpaid federal taxes. The bankruptcy trustee for Century Boat objected to the claim on the basis of its untimeliness, and the bankruptcy court sustained the objection. The district court affirmed the decision of the bankruptcy court, holding that the failure of the Internal Revenue Service to file its proof of claim promptly after receiving notice of the bankruptcy deprived it of priority distribution under 11 U.S.C. § 726(a)(1). The…