MEMORANDUM ON TRUSTEE’S OBJECTION TO CLAIM FILED BY INTERNAL REVENUE SERVICE
The trustee in these consolidated Chapter 7 cases, N. David Roberts, Jr., objects to the allowance of a proof of claim filed by the Internal Revenue Service (IRS) in the amount of $42,134.44. The trustee contends that, because the IRS filed its claim after the bar date, it should be entitled to payment only after payment of all other allowed unsecured claims pursuant to Bankruptcy Code § 726(a)(3). Conversely, the IRS argues that to the extent its claim is a priority claim under Code § 507(a)(7), it is entitled to payment within the, first level of distribution required under § 726(a)(1).1 If the IRS claim is entitled to payment under § 726(a)(1), the trustee will have no funds left to pay to unsecured nonpriority creditors whose timely-filed claims are entitled to payment under § 726(a)(2).
All facts and documents essential to a resolution of the issues before the court are stipulated by the parties in a “Joint Stipulation Of Facts And Exhibits” filed on September 30, 1993.
This is a core proceeding. 28 U.S.C.A. § 157(b)(2)(B) (West 1993).
I
An involuntary petition was filed against Edelen Transfer and Storage Company on *877July 2,1990. An order for relief was entered under Chapter 7 on July 26, 1990, and N. David Roberts, Jr., was appointed trustee. No statements or schedules were filed and creditors, accordingly, did not receive notice of the pendency of this case or of the setting of any creditors’ meeting or claims bar date.
Three days later, on July 5, 1990, the Larry Merritt Company, a Tennessee Corporation, filed a voluntary petition under Chapter 7.2 The debtor filed with this petition the required statements and schedules together with a master address list of creditors. On July 12,1990, N. David Roberts, Jr., was also appointed trustee in this case.
The debtor listed the IRS and the United States Attorney in Schedule A-l to its petition as a priority creditor as follows:
Internal Revenue Service
Special Procedures
P.O. Box 1107
Nashville, TN 37202
John Gill, United States Attorney
Ste. 700, Plaza Tower
Knoxville, TN 37929
941/940 Taxes $25,000.00
Although the master address list filed by the debtor contained the proper address of the IRS as listed above, it contained an incomplete address for the United States Attorney:
U.S. Attorney
P.O. Building
Knoxville, TN 37901
The clerk mailed the notice for the meeting of creditors to parties in interest in the Larry Merritt Company case, including the IRS, on July 10, 1990. The mailing certificate shows that the notice was sent to the IRS and United States Attorney at the addresses contained in the debtor’s master address list.
The July 10,1990 notice provided creditors with notice that the creditors meeting would be held on August 14, 1990, and that the last date to file a proof of claim was November 13, 1990. No representative of the IRS appeared at the creditors meeting nor did the IRS timely file a claim. On August 24,1990, upon motion of the United States Trustee, the cases of Larry Merritt Company and Edelen Transfer And Storage Company were consolidated.
The debtor did not file with the IRS its 1989 and 1990 Form 940, Employer’s Annual Federal Unemployment Tax Returns, or Form 941, Employer’s Quarterly Federal Tax Returns, until January 14, 1991. Prior to receipt of the returns, the IRS tax examiner assigned to the debtor’s bankruptcy case was under the mistaken belief that the balance of taxes owed by the debtor was below the IRS’ internal criteria for filing a proof of claim. The IRS filed its proof of claim, designated as Claim No. 37, on April 5,1991, almost five months after expiration of the November 13, 1990 claims bar date. By its claim, the IRS asserts a priority claim against the debtor under 11 U.S.C.A. § 507(a)(7) (West 1993) for payroll taxes in the amount of $32,150.40 and a general nonp-riority unsecured tax penalty claim in the amount of $9,984.04.3 The entire claim is grounded upon the unpaid prepetition payroll taxes owed by the debtor for 1989 and 1990.
*878II
Relying on two Sixth Circuit decisions, IRS v. Century Boat Co. (In re Century Boat Co.), 986 F.2d 154 (1993), and United States v. Cardinal Mine Supply, Inc., 916 F.2d 1087 (1990), the IRS contends that the priority portion of its late-filed claim should be paid in the first level of distribution under § 726(a)(1).
The debtors in both Century Boat and Cardinal Mine Supply failed to schedule the IRS as a creditor and the IRS failed to receive notice of the bankruptcy filings until approximately two years after expiration of the bar dates for filing claims.4 The Sixth Circuit held that the IRS was nonetheless entitled to receive distribution of its priority claims under § 726(a)(1) rather than under § 726(a)(2) or (3).5
In Century Boat, the court noted that, had the IRS received notice and timely filed its proof of claim, the claim would have been entitled to priority of payment under § 507(a)(7) and the IRS would have received distribution under § 726(a)(1). Citing its earlier Cardinal Mine Supply decision, the court concluded that “section 726(a)(1), concerning distribution of priority claims, makes no distinction between priority claims which are filed late and those which are filed in a timely manner.” 986 F.2d at 157. Further, the court stated that “[w]here ... the reason for late filing of a priority claim is the failure to give the creditor notice, it should be treated the same as timely filed priority claims entitled to distribution under section 726(a).” 986 F.2d at 158 (quoting Cardinal Mine Supply, 916 F.2d at 1092).
In Century Boat, the Sixth Circuit emphasized that Cardinal Mine Supply established a “narrow exception” to the distribution scheme required by § 726(a) affecting priority creditors “who lack notice of the bankruptcy.” 986 F.2d at 158. The court noted that not every priority creditor lacking notice whose claim is tardily filed can invoke the holding of Cardinal Mine Supply. The court held that “[a]t a minimum, the creditor must file its proof of claim before the trustee makes any distribution from the estate and before the bankruptcy court closes the estate”; that “the creditor may not receive priority distribution under Cardinal Mine Supply if the court finds evidence of bad faith on the part of the creditor or undue prejudice to other creditors [or] other factors ... warrant equitable subordination of the priority claim.” Id.
ADEQUATE NOTICE
The IRS contends it did not receive adequate notice of the commencement of the debtor’s bankruptcy case. It argues that the Local Rules of this court mandate that all notices required to be sent to the IRS must also be sent to the United States Attorney. Specifically, the IRS relies on Rules 2 and 3 of the Local Rules Of Practice And Procedure For The United States Bankruptcy Court For The Eastern District Of Tennessee.6
*879The Local Rules provide that the master address list provided by the debtor is required to contain the address of the IRS and the addresses of parties who are entitled to notice under Fed.R.Bankr.P. 2002(j), including the United States Attorney for the Eastern District of Tennessee.7 It is undisputed that the master address list in the instant case accurately set forth the address of the IRS and that the IRS received timely notice of the bankruptcy case. It is also undisputed that the master address list contained an incomplete and, therefore, insufficient address for the United States Attorney.
The IRS argues that in the absence of notice to the United States Attorney it had no notice of the filing of the debtor’s Chapter 7 petition. Consequently, it contends that the holdings of the Sixth Circuit in Century Boat and Cardinal Mine Supply require that its claim in the amount of $32,150.40 be allowed and paid as a priority claim under Code §§ 507(a)(7) and 726(a)(1).
This argument is without merit. Bankruptcy Rule 2002(j)(3) requires that the IRS receive all notices in a Chapter 11 case, whether or not there are tax claims involved in the ease. Bankruptcy Rule 2002(j)(4) requires notice if the “papers in the case” reflect “a debt to the United States other than for taxes ” (emphasis added). Fed.R.Bankr.P. 2002(j)(4). Under Rule 2002(j)(4), service of the notice must be sent to both “the United States Attorney for the district in which the case is pending and to the department, agency or instrumentality of the United States through which the debtor became indebted.... ” Id.
Failure to provide notice both to the United States Attorney and to the affected governmental entity when required by Rule 2002(j)(4) is fatally defective. See In re Interstate Cigar Co., 150 B.R. 305, 309 (Bankr.E.D.N.Y.1993) (“Bankruptcy Rule 2002(j)[ (4) ] clearly requires that notices of bar dates to governmental departments, agencies or instrumentalities be sent to the entity in question and the U.S. Attorney located in the relevant district”); In re Divco Philadelphia Sales Corp., 60 B.R. 323 (Bankr.E.D.Pa.1986) (Notice to the Pension Benefit Guaranty Corporation was defective and the bar date for filing claims did not bind the pension fund when notice was not also sent to the United States Attorney as required by Bankruptcy Rule 2002(j)(4)).
The IRS misconstrues Bankruptcy Rule 2002® and Local Rules 2 and 3. Local Rules 2 and 3 do not expand the requirements of Rule 2002®. If the debtor owes only taxes, the United States Attorney need not receive notice; then, only the IRS is required to receive notice. See In re Hejl, 85 B.R. 399, 400 (Bankr.W.D.Tex.1988).
Because the debtor in the instant case owed only taxes to the IRS, notice to the United States Attorney was not required. Accordingly, failure of the United States Attorney to receive notice of the November 13, 1990 bar date for filing claims did not make the notice to the IRS defective. The court therefore finds that the “narrow exception” carved out by the Sixth Circuit in Cardinal Mine Supply and Century Boat for priority creditors who lack notice of the bankruptcy case has no application to the instant proceeding. The IRS timely received notice of the November 13, 1990 claims bar date.
EFFECT OF DEBTOR’S FAILURE TO TIMELY FILE TAX RETURNS
The IRS further contends that the debtor’s failure to timely file the required 1989 and 1990 tax returns serves to automat*880ically extend the claims bar date to permit allowance of its priority claim as timely filed.
Bankruptcy Rule 3002(e) governs the time for filing a proof of claim in a Chapter 7 case. That Rule provides for an extension of the ninety-day claims bar date for six specific reasons, including, for cause, upon motion of the IRS filed before expiration of the ninety-day period.8 Bankruptcy Rule 9006(b)(3) states that enlargement of the ninety-day time period established by Rule 3002(c) may occur only to the extent and under the conditions permitted by Rule 3002(c).9 One of the conditions under Rule 3002(e)(1) is that the request for extension of the ninety-day period be made by the IRS “before the expiration of such period.” This court simply has no discretion to treat the IRS claim in the instant proceeding as timely filed when the IRS received notice and no extension was requested prior to expiration of the November 13, 1990 claims bar date. See Norwest Bank Worthington v. Ahlers, 485 U.S. 197, 206-07, 108 S.Ct. 963, 969, 99 L.Ed.2d 169 (1988) (“[W]hatever equitable powers remain in the bankruptcy courts must and can only be exercised within the confines of the Bankruptcy Code”) See also Ray v. City Bank & Trust Co. (In re C-L Cartage Co.), 899 F.2d 1490, 1494 (6th Cir.1990) (“Bankruptcy courts ... cannot use equitable principles to disregard unambiguous statutory language.”).
This result cannot be considered harsh to the IRS. With notice of the bankruptcy case, it made a conscious decision not to timely file a claim even though the debtor was indebted to it. The debtor’s schedules, had they been reviewed, clearly evidenced a substantial liability for the 1989 and 1990 payroll taxes.
The IRS is a sophisticated party in bankruptcy cases. It is not unusual for a debtor to be delinquent in the filing of tax returns upon the commencement of a bankruptcy case. Within this district, the IRS regularly files estimated tax claims on a timely basis which it thereafter amends when the debtor’s tax liability is finally determined. As stated by Justice Thomas in Taylor v. Freeland & Kronz, — U.S.-,-, 112 S.Ct. 1644, 1648, 118 L.Ed.2d 280 (1992), “[d]eadlines may lead to unwelcome results, but they prompt parties to act and they produce finality.” Given the fact that the IRS had notice of the debtor’s bankruptcy case and that it is accorded a right under Bankruptcy Rule 3002(c) to request an extension of the ninety-day claims bar date, it cannot complain.
Ill
The IRS relies on other authority in support of its contention that its claim should be allowed and paid as a priority claim. As the court believes that the “narrow exception” carved out by the Sixth Circuit in Century Boat for construing Cardinal Mine Supply is dispositive of the trustee’s objection, it need not address these other issues.
This Memorandum constitutes findings of fact and conclusions of law as required by Fed.R.Bankr.P. 7052. An order will be entered sustaining the trustee’s objection and allowing the IRS claim, as to the debtor’s liability for Forms 940 and 941 taxes for 1989 and 1990, as tardily filed under § 726(a)(3) in the amount of $32,150.40. The penalty por*881tion of the claim, $9,984.04, will be allowed under § 726(a)(4).