The court granted summary judgment to the IRS in this adversary proceeding in which the plaintiffs, who held a claim against the bankruptcy estate for unpaid ERISA plan payments, sought to use equitable estoppel or equitable subordination to move their claim ahead of the IRS’s administrative expense claim for unpaid post-petition payroll taxes. The court held that the plaintiffs had “not borne their burden of proving each of the necessary elements of equitable subordination or equitable estoppel, in particular the existence of misconduct on the part of the IRS.”