(Chapter 12 case; debtor and brother formed co-equal farm partnership in 1993 that owned livestock and machinery used in farming; partnership dissolved in late 2010 and debtor continued farming a smaller farming operation; debtor then filed Chapter 12; both IRS and state (IA) Dept. of Rev. (IDOR) filed priority claim for pre-petition taxes arising from partnership dissolution which they treated as sale of "partnership interest" rather than sale of "farm assets" which, therefore, would not be entitled to non-priority treatment in accordance with 11 U.S.C. Sec. 1222(A)(2)(a); debtor's expert witness attempted to characterize debtor's partnership as not a partnership for tax purposes due to the small partnership exception of I.R.C. Sec. 6231(a)(1)(B) and, thus, partnership is treated as non-existent and debtor's income arose from sale of personal interest in farm partnership rather than capital interest in partnership; court rejected testimony of defendant's expert witness as irrelevant and stated, "...the decision here will not rely in any way on his testimony."; court noted that small partnership exception enacted in 1982 as part of TEFRA was enacted to implement unified audit examination and litigation provisions which centralized treatment of partnership taxation issues and ensured equal treatment of partners by uniformly adjusting tax liability of partners; while court noted that some statutory language may be supportive of position of debtor's expert, expert's position was not dispositive of the issue, given much case law and legislative language contrary to such position including judicial opinions noting the effect of TEFRA and small partnership exception was to keep the old rules in place for small partnerships rather than create new ones; ultimately, court determined that 11 U.S.C. Sec. 1222(A)(2)(a) applied to sale of farm assets in general, including capital assets used in farming; because underlying assets that were sold were farm assets, they are covered by 11 U.S.C. Sec. 1222(A)(2)(a) as determined by Eighth Circuit inKnudsen, et al. v IRS, 581 F.3d 696 (8th Cir. 2009); U.S. Supreme Court decision in Hall v. United States, 132 S. Ct. 1882 (2012) did not overrule Knudsen on issue of definition of "farm assets" for purposes of 11 U.S.C. Sec. 1222(A)(2)(a); debtor's farm partnership interest was "used in" the farm partnership farming operation - debtor farmed by using farm partnership interest; 11 U.S.C. 1222(A)(2)(a) not limited in application to farming operation under the reorganization plan; debtor meets all other requirements for Chapter 12 bankruptcy; defendants' objections to debtor's confirmed Chapter 12 plan overruled).