Case appealed from bankruptcy court to district court.  District court affirmed bankruptcy court's ruling.  Parties later entered into partial settlement agreement but reserve issues related to interest due for underpayment of taxes and bankruptcy court issued a certification for direct appeal to Circuit Court.  Circuit accepted direct appeal.

Debtor owed interest due to underpayment of taxes for tax year 1998.  Tax court issued a determination as to deficiency amount due for tax year 1998 but did not include a determination of interest owed.  Government later included interest in total amount due for tax year 1998.  Debtor objected to calculation and bankruptcy determined that tax court decision was final and determinative of amounts owed for tax year 1998 and that it was improper for government to include interest in calculation of amounts due and owing because such amounts were not determined by the tax court.