Galletti

ORDER AND AMENDED OPINION

ORDER

The opinion filed August 8, 2002, 298 F. 3d 1107 , is amended as follows:

On slip opinion page 11556, just before the summary paragraph, add the following two paragraphs:

With this amendment, the panel has voted to deny the petition for rehearing. Judges Kleinfeld and Graber have voted to deny the petition for rehearing en bane, and Judge Bolton has so recommended.

The full court has been advised of the petition for rehearing en bane and no judge of the court has requested a vote on it.

The petition for rehearing and petition for rehearing en bane are DENIED. No further petitions for rehearing or rehearing en banc may be filed.

OPINION

Debtors Abel Cosmo Galletti, Sarah Galletti, Francesco Briguglio, and Angela Briguglio filed Chapter 13 bankruptcy petitions. The United States Internal Revenue Service (IRS) filed proofs of claim against Debtors for unpaid employment taxes assessed against a partnership in which Debtors were general partners. The bankruptcy court disallowed the IRS’s claims, and the district court affirmed. We also affirm. The IRS’s claims were properly disallowed because (1) the IRS cannot collect a partnership’s tax…