UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

In re: Case No: 20-10934-EPK

GLENN, CHRISTOPHER Chapter 13

XXX-XX-1876

GLENN, ROCHELLE

XXX-XX-6314

Debtors

_____________________________/

DEBTOR’S MOTION TO PAY INTEREST ON DEPARTMENT OF THE

TREASURY-INTERNAL REVENUE SERVICE’S PRIORITY CLAIM

The Debtors, Christopher and Rochelle Glenn, by and through the undersigned attorney, 

file this Motion to Pay Interest on Department of the Treasury-Internal Revenue Service Priority 

Claim (POC#7) and states:

1. The Department of the Treasury-Internal Revenue Service is owed a priority tax claim as 

set forth in Proof of Claim#7. The Department of the Treasury-Internal Revenue Service 

takes the legal position that interest accrues on said amount over the Chapter 13 Plan period 

and that the accrued interest is non-dischargeable.

2. The accrual of said non-dischargeable interest severely hampers the Debtor’s ability to 

effectually reorganize and jeopardizes her fresh start. Thus, the Debtor seeks to pay the 

Department of the Treasury/IRS 5.00% interest on the priority claim amount as set forth in 

Proof of Claim#7 (or any future amendments thereto) through the Chapter 13 Plan.

3. The undersigned counsel requests attorney’s fees/costs of $525.00 as a result of filing this 

motion.

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WHEREFORE, the Debtor respectfully requests that this Court enter and Order: (1) 

allowing the Debtor to pay the Department of the Treasury/IRS 5.00% interest on any priority 

claim amount in Proof of Claim#7, through any Chapter 13 Plan, (including amended or 

modified plans); (2) approving $525.00 in attorney’s fees/costs; and (3) such other and further 

relief as the Court may deem just and proper. 

I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for 

the Southern District of Florida and that I am in compliance with the additional qualifications to 

practice in this Court as set forth in Local Rule 2090-1(A).

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to 

Robin Weiner, Trustee, PO Box 559007, Ft. Lauderdale, FL 33355 and Office of the U.S. 

Trustee, 51 S.W. First Ave., Ste 1204, Miami, FL. 33130, The Department of the TreasuryInternal Revenue Service P.O. Box 7346, Philadelphia, PA. 19107-7346; Loretta E. Lynch, 

Attorney General of the United States: 950 Pennsylvania Ave., NW, Room 4400, Washington 

D.C. 20530; Hon. Wilfredo A. Ferrer, United States Attorney, Southern District of Florida: 99 NE 

4

th St. Miami, FL. 33132; Special Assistant United States Attorney, Associate Area Counsel 

(SBSE) Ft. Lauderdale, 1000 South Pine Island Road, Ste 300, Plantation, FL. 33324; Civil 

Process Clerk-Attorney General of the United States-Southern District of Florida, 99 NE 4 St 

Miami, FL. 33132; and all creditors on the attached creditor matrix this 15th day of August 2019.

THE PORT LAW FIRM, P.A.

Attorney for the Debtor(s)

2161 Palm Beach Lakes Blvd., Suite 202

West Palm Beach, FL 33409

Tel: (561) 721-1212

FAX: (888) 411-0092

By: /s/ Edward N. Port 

Edward N. Port, Esq.

For The Firm

Florida Bar No. 988588

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