Ralph H. Drake, Jr. v. United States of America, on Behalf of Internal

SUMMARY ORDER

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment is AFFIRMED.

Appellant Ralph H. Drake, Jr., a debtor under Chapter 7 of the U.S. Bankruptcy Code, objects to a proof of claim filed by the Internal Revenue Service (“IRS”). The Bankruptcy Court (Littlefield, Jr., J.) denied Drake’s objection, and the District Court (Kahn, J.) affirmed the Bankruptcy Court’s decision. We assume the parties’ familiarity with the facts, procedural history, and issues on appeal.

The government argues that we should vacate the judgment of the district court because the…