by the United States government

“ The debtor shall have the burden of proving, by clear and convincing evidence, that— (A) the creditor unreasonably refused to consider the debtor’s proposal; and (B) the proposed alternative repayment schedule was made prior to expiration of the 60-day period specified in paragraph (1) (B) (i) . ”

“ A claim that does not arise until after the commencement of the case for a tax entitled to priority under section 507 (a) (8) of this title shall be determined, and shall be allowed under subsection (a) , (b) , or (c) of this section, or disallowed under subsection (d) or (e) of this section, the same as if such claim had arisen before the date of the filing of the petition. (j) A claim that has been allowed or disallowed may be reconsidered for cause. A reconsidered claim may be allowed or disallowed according to the equities of the case. ”