Quattrone Accountants, Inc. v. United States (In Re Quattrone Accountants, Inc.)

MEMORANDUM OPINION

BERNARD MARKOVITZ, Bankruptcy Judge.

Presently before the Court is Debtor’s Objection to the Claim of the Internal Revenue Service (“IRS”), and a Complaint to Determine Tax Liability of Debtor and Phillip P. Quattrone. 1

Debtor disputes its identification, for tax assessment purposes, as a “responsible person” of the United Dairy Farmers Cooperative Association (“UDF”). Alternatively, Debtor contends that the IRS must first seek to satisfy the tax debt through UDF, and that Debtor should only be assessed, if at all, to the extent UDF is unable to cure the default. Debtor’s…