7      “General rules of statutory construction provide thatwhere two statutes  conflict, thespecific governs over the general.” In re Roberts, 594 B.R. 484, 491  (Bankr. N.D. Fla. 2018) (emphasis added); see also RadLAX Gateway Hotel, LLC  v. Amalgamated Bank, 566 U.S. 639, 645 (2012) (“[I]t is a commonplace of  statutory construction that the specific governs the general.”) (alteration in  original) (quoting Morales v. Trans World Airlines, Inc., 504 U.S. 374, 384  (1992)). Since § 553(a) is a statute of general applicability and § 1232(a) deals  with specific scenarios, § 1232(a) will control if there is a conflict between the two  statutes.  The Court now therefore determines whether the two statutes actually  conflict. On its face, § 1232(a) says nothing about clawing back tax witholdings.  The usual effect of the section is to reset qualifying tax debts as ordinary  unsecured, non-priority debts. See also Knudsen v. I.R.S., 581 F.3d 696, 718 (8th  Cir. 2009) (abrogated on other grounds) (referring to the predecessor of § 1232 as  “a priority-stripping provision as opposed to a tax provision”). However, the full  effects of § 1232(a) are left a bit unclear under the plain language of the statute.  Congress did not elaborate on statements that qualifying tax debt “shall be treated  as an unsecured claim” and “shall not be entitled to priority,” which are unclear as  to their effect here. 11 U.S.C. § 1232(a)(1)-(2). These statements are ambiguous  when applied here to the question before the Court. In § 1232(a)(3) and (4),  Case 19-00181 Doc 105 Filed 04/28/20 Entered 04/28/20 13:08:49 Desc Main  Document Page 7 of 13

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