Southeast Waffles, LLC v. United States Department of Tr

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OPINION and JUDGMENT filed : The judgment of the Bankruptcy Appellate Panel is AFFIRMED. Decision for publication. Danny J. Boggs and Eric L. Clay, Circuit Judges; and William H. Stafford (AUTHORING), U.S. District Judge for the Northern District of Florida, sitting by designation.

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Case: 11-6522 Document: 006111522501 Filed: 12/06/2012 Page: 1 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT 100 EAST FIFTH STREET, ROOM 540 POTTER STEWART U.S. COURTHOUSE CINCINNATI, OHIO 45202-3988 Deborah S. Hunt Clerk Tel. (513) 564-7000 www.ca6.uscourts.gov Filed: December 06, 2012 Mr. Jonathan S. Cohen Ms. Rachel I. Wollitzer U.S. Department of Justice Tax Division, Appellate Section P.O. Box 502 Washington, DC 20044 Mr. Glenn B. Rose Harwell, Howard, Hyne, Gabbert & Manner 333 Commerce Street, Suite 1500 Nashville, TN 37201 Mr. Andrew C. Strelka U.S. Department of Justice PO Box 227 Washington, MI 20044 Re: Case No. 11-6522, Southeast Waffles, LLC v. U.S. Dep’t of Treasury/IRS Originating Case No. : 3:08-bk-07552 Dear Counsel, The court today announced its decision in the above-styled case. Enclosed is a copy of the court's opinion together with the judgment which has been entered in conformity with Rule 36, Federal Rules of Appellate Procedure. Yours very truly, Deborah S. Hunt, Clerk Cathryn Lovely Deputy Clerk Case: 11-6522 Document: 006111522501 cc: Mr. Keith Throckmorton Enclosures Mandate to issue. Filed: 12/06/2012 Page: 2

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