MEMORANDUM DECISION ON REMAND OF THE CHAPTER 7 TRUSTEE'S OBJECTION TO PROOF OF CLAIM #6 (INTERNAL REVENUE SERVICE) LAURA S. TAYLOR , Chief Judge , United States Bankruptcy Court. This matter comes before the Court on remand from the Bankruptcy Appellate Panel of the Ninth Circuit ("BAP") and presents a narrow question: When a chapter 7 1 trustee (the "Trustee") incurs a statutory penalty for his unreasonable failure to timely file federal tax returns for an S corporation debtor, should...