In re Ford

OPINION AND ORDER ON DEBTORS’ REMAINING OBJECTION TO THE CLAIM OF THE IRS

BARBARA J. SELLERS, Bankruptcy Judge.

This matter is before the Court on the objection of debtors Jon and Patricia Ford to the proof of claim filed by The United States of America, Internal Revenue Service (“IRS”). Specifically, the debtors maintain that IRS has not applied income tax refunds *174due debtors for 1986 and 1987 to reduce their tax liabilities. The IRS maintains that with respect to taxable years 1986 and 1987, such refunds are barred by the provisions of 26 U.S.C. § 6511.

Section 6511 of 26 U.S.C. imposes two…