MEMORANDUM DECISION
PETER H. CARROLL, Bankruptcy Judge.
On May 14, 2013, the United States Department of Treasury — Internal Revenue Service ("IRS") filed an amended proof of claim ("Claim # 1-3") in the above referenced case asserting an unsecured priority claim under § 507(a)(8)(D) in the amount of $2,322,545.20. Debtor, Intercare Health Systems, Inc. ("Intercare") objects to the priority sought by the IRS, asserting that the three year period...
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