United States Bankruptcy Court, S.D. Texas January 22, 2002, No. 99-23632-C-11 (In re Sewickley Hospitality, Ltd.)

OPINION RECONSIDERING THE GRANTING OF SUMMARY JUDGMENT

RICHARD S. SCHMIDT, Bankruptcy Judge.

Before the Court is the Debtors request for reconsideration of the Granting of Summary Judgment in favor of the Internal Revenue Service (IRS). After the debtor objected to the IRS’s proof of *128claim, cross motions for Summary Judgment were filed by the debtor and the IRS.