MEMORANDUM OPINION AND ORDER
The court is asked to accord comity to a Luxembourg court judgment that would permit plaintiff to satisfy a U.S. income tax obligation by paying 23.49% of the taxes owed. Because the court concludes that recognizing such a decree would run counter to U.S. public policy, the court declines to accord comity to the Luxembourg judgment and denies plaintiff’s motion for summary judgment.
I.
BACKGROUND
Plaintiff, Overseas Inns S.A. P.A. (“Overseas”), a Luxembourg corporation headquartered in Luxembourg City, Luxembourg, sues to recover income taxes that Overseas contends the Internal Revenue Service (“IRS”) “wrongfully, erroneously and illegally” assessed and collected.1 Overseas is the successor to Western Sales Limited (“Western”), a Bahamian company. On July 12,1973, Overseas, as successor to Western, filed U.S. foreign corporation income tax returns for calendar years 1960, 1961, and 1962. Overseas filed the returns, which stated that no tax was due, “solely in *969order to prevent the possible loss of deductions and credits under Internal Revenue Code § 882.” The IRS contended that Western had engaged in trade or business in the United States during these years and had derived income from U.S. sources, a proposition which Overseas challenged.
In early 1976, the IRS issued a statutory notice of deficiency within the time prescribed by 26 U.S.C. § 6501. Overseas timely filed a petition with the U.S. Tax Court. The Tax Court proceeding was pending on December 16, 1977 when Overseas was placed in a bankruptcy-like status in Luxembourg.
At a public hearing, the Luxembourg court2 appointed commissaires3 who were ordered to establish, by April 1, 1978, a plan of reorganization or plan of distribution to liquidate completely Overseas’ assets. The Luxembourg court vested the management of Overseas under the control of the commissaires and ordered them to compile an inventory of the assets under “controlled management” and to prepare a statement of assets and liabilities and balance sheets for the company. The court ordered the commissaires to communicate the plan “to the corporation’s known creditors, co-debtors and guarantors.”
In the meantime, the IRS and Overseas compromised the proposed deficiencies and penalties. The U.S. Tax Court, on January 27, 1978, entered a deficiency determination which, as of March 13, 1978, equaled $1,003,724.61, including accrued interest. On that date Overseas’ proposed plan of reorganization indicated that the IRS held an unsecured claim in that amount. According to the proposal, Overseas planned to pay the IRS the equivalent of approximately $231,475.00, or 23.49% of the income tax deficiency.
On December 20,1978, the commissaires submitted to the Luxembourg court their proposed plan of reorganization and Overseas sent a copy of the plan to the IRS. The IRS did not file an objection to the proposal. At a January 25, 1979 public hearing, the Luxembourg court rendered its written judgment, which was published in an official gazette on February 9, 1979.
It is undisputed that the Luxembourg court had jurisdiction to decide the Overseas reorganization. The parties have stipulated that the Luxembourg court, the commissaires, and Overseas committed no fraud in the receivership proceeding or in the handling or disposition of the amount owed to the IRS or any other creditor. The parties have also stipulated that Overseas acted lawfully under Luxembourg law in executing its obligations under the reorganization plan and in all matters arising out of or in connection with the receivership.
In March 1979, Overseas sent the IRS a check in the amount of 2,402,940 Belgium Francs, which constituted an initial payment of taxes. Overseas also delivered five promissory notes, each in the amount of 961,176 Belgium Francs, which notes provided for payment in equal yearly installments, without interest, beginning in February 1980. The IRS returned the initial payment because it was not payable in U.S. funds; Overseas thereafter remitted U.S. funds. Between May 1979 and March 1983, Overseas made six payments which totaled $179,135.76.
In June 1981, Overseas and a third party agreed that the third party would purchase 19% of the issued and outstanding stock of a corporation owned by Overseas. The purchaser agreed to pay part of the purchase price in cash and to pay the balance in semi-annual installments. In June 1983, the third party was to pay $247,605.48; in response to an IRS notice of levy, however, the purchaser paid the sum to the IRS. This notice of levy and payment procedure recurred in December 1983, June 1984, and December 1984. In March 1984, Overseas placed in escrow the last payment due under the reorganization plan, subject to the terms of an agreement between the government and Overseas. Overseas thereafter filed suit in the U.S. District *970Court for the District of Columbia, which transferred the case to this court.
Overseas contends it satisfied its obligation to the government by paying the sum of $179,135.76 in accordance with the Luxembourg court-approved plan of reorganization; it posits that the government, by means of the IRS levies, has collected an additional $919,835.79 to which the government is not entitled.4
Overseas now moves for summary judgment, contending this court should accord comity to the Luxembourg court’s judgment and, in turn, hold that Overseas has fully satisfied its U.S. income tax obligations and that the government wrongfully collected the additional sums. Overseas asserts that U.S. courts, for a variety of reasons, now consistently recognize the interest of foreign courts in liquidating or winding up the affairs of their own domestic entities and in providing a single, final proceeding in which all the affairs of a debtor may be resolved with a single judgment. Overseas suggests that U.S. recognition of foreign reorganizations may enhance certainty and predictability for the debtor, its creditors, and potential investors. Overseas also argues that, because it had only nominal U.S. assets at the time of its reorganization, and only a post-reorganization event (sale of subsidiary stock) generated funds in the United States, the success of the IRS will injure Overseas’ post-bankruptcy creditors and owners who were not necessarily involved with Overseas when it emerged from reorganization.
The government opposes recognizing the Luxembourg decree, contending the IRS was not afforded due process by the Luxembourg court,5 that courts do not grant extraterritorial effect to decisions in foreign bankruptcy proceedings where to do so would prejudice the interests of the United States or its citizens (and that Luxembourg law is materially different in its treatment of the IRS than is U.S. law), that Overseas failed to avail itself of the option available under 11 U.S.C. § 304 to maintain an ancillary bankruptcy proceeding in the United States, the Luxembourg court-approved plan does not cover assets located in the United States that are “after-acquired” assets, and the relevant Luxembourg law is against public policy.
II.
DISCUSSION
A.
The doctrine of comity was defined by the Supreme Court in the seminal case of Hilton v. Guyot, 159 U.S. 113, 163-64, 16 S.Ct. 139, 143, 40 L.Ed. 95 (1895):
“Comity,” in the legal sense, is neither a matter of absolute obligation, on the one hand, nor of mere courtesy and good will, upon the other. But it is the recognition which one nation allows within its territory to the legislative, executive or judicial acts of another nation, having due regard both to international duty and convenience, and to the rights of its own citizens or of other persons who are under the protection of its law.
Comity is a recognition, a rule of practice, convenience, and expediency; it does not achieve the force of imperative or obligation, but rather constitutes “a nation’s expression of understanding which demonstrates due regard both to international duty and convenience and the rights of persons protected by its own laws.” Somportex Ltd. v. Philadelphia Chewing Gum Corp., 453 F.2d 435, 440 (3d Cir.1971), cert. denied, 405 U.S. 1017, 92 S.Ct. 1294, 31 L.Ed.2d 479 (1972). Comity “summarizes in a brief word a complex and elusive concept — the degree of deference that a domestic forum must pay to the act of a foreign government not otherwise binding on the forum.” Laker Airways Ltd. v.
*971 Sabena, Belgian World Airlines, 731 F.2d 909, 937 (D.C.Cir.1984).6
' “[Transnational insolvency cases have been rarely submitted for formal adjudication in U.S. courts [and] the law in this complex field remains underdeveloped and inconsistent at best.” Morales & Deutcsh, Bankruptcy Code Section 304 ^md U.S. Recognition of Foreign Bankruptcies: The Tyranny of Comity, 39 Bus.Law. 1573, 1575 (1984) [“Morales & Deutcsh”]. Indeed,
American courts have been faced with the issue of how much recognition to grant foreign insolvency proceedings almost from the time the country was founded. Even though the problem is far from new, surprisingly few have adjudicated the issue [and] have been forced to rely on very old cases ... since so little guidance has developed in this area.
Unger, United States Recognition of Foreign Bankruptcies, 19 Int’l Law. 1153, 1156 (1985) [“Unger”]. For a century, the international law doctrine of comity provided a vague standard for resolving such international jurisdictional conflicts, producing mixed results. Morales & Deutcsh, 39 Bus.Law. at 1576. Because of the relative infrequency with which United States courts have had to deal with multinational bankruptcies, the subject has received about as much professional attention “as did letters of marque and reprisal." Gitlin & Flaschen, The International Void in the Law of Multinational Bankruptcies, 42 Bus.Law. 307, 314 (1987) [“Gitlin & Flaschen”] (quoting Becker, Transnational Insolvency Transformed, 29 AmJ.Comp.L. 706, 707 (1981)).
Two contrasting doctrines have emerged regarding the recognition of foreign bankruptcy decisions:7 the universality theory and the territoriality theory. The universality theory recognizes in its purest form “that all of the debtor’s assets wherever located be subject to the exclusive jurisdiction of the court in which the bankruptcy case is pending.” Gitlin & Flaschen, 42 Bus.Law. at 309. According to this doctrine, “the laws of the state where the original bankruptcy case is situated should be recognized everywhere.” Id. The terri*972toriality theory, on the other hand, “posits that bankruptcy laws should not be recognized beyond a state’s borders.” Id.
As might be expected, Overseas asks the court to adopt the universality approach in the present case. Overseas contends that, with exceptions,8 American courts have recently embraced the universality theory and have granted comity to foreign bankruptcy judgments. See, e.g., In re Enercons Virginia, Inc., 812 F.2d 1469 (4th Cir.1987) (comity extended to Italian proceedings); Cunard S.S. Co. v. Salen Reefer Services A.B, 773 F.2d 452 (2d Cir.1985) (dismissal based on Swedish bankruptcy); Daniels v. Powell, 604 F.Supp. 689 (N.D.Ill. 1985) (mere fact that foreign law is not identical insufficient to preclude comity); Kenner Products Co. v. Societe Fonciere et Financiere Agache-Willot, 532 F.Supp. 478 (S.D.N.Y.1982) (action suspended pending termination of French bankruptcy); Cornfeld v. Investors Overseas Services, Ltd., 471 F.Supp. 1255 (S.D.N.Y.1979) (dismissal based on Canadian bankruptcy).9
To decide the present case, the court need not adopt one approach to the exclusion of the other. The court concludes, even ünder the universality theory, that U.S. public policy considerations10 reason against recognizing a foreign decree that adversely affects a U.S. government tax claim.
B.
It is a settled principal of comity that deference need not be given to foreign judgments in the face of significant countervailing public policy reasons.11
[A] foreign judgment not entitled to full faith and credit under the Constitution will not be enforced within the United States when contrary to the crucial public policies of the forum in which enforcement is requested. Both rules recognize that a state is not required to give effect to foreign judicial proceedings grounded on policies which do violence to its own fundamental interests.
Laker Airways, 731 F.2d at 931 (footnotes omitted). This has been the rule since 1895. Id. at 937; Hilton, 159 U.S. at 163-164, 16 S.Ct. at 143. See Gitlin & Flaschen, 42 Bus.Law. at 320 (where public policy considerations have come into play the courts have declined to exercise comity).
It is beyond peradventure that there is, in the United States, an inexpugnable public policy that favors payment of lawfully owed federal income taxes. See H.R. Conf.Rep. No. 841, 99th Cong., 2d Sess. 11-777, reprinted in 1986 U.S.Code Cong. *973& Ad.News 4075, 4865. Similarly, the legislative history to the Bankruptcy Code12 reflects a strong policy in favor of payment of taxes, even when the taxpayer has filed for bankruptcy. See S.Rep. No. 989, 95th Cong., 2d Sess. 1,13-15, reprinted in 1978 U.S.Code Cong. & Ad.News 5787, 5799-5801.13
Overseas argues, however, that the IRS would not have fared better in U.S. bankruptcy court and there is thus no reason to dishonor the Luxembourg decree on that basis.14 Overseas reasons that, while former Bankruptcy Act15 Chapter X § 199 [11 U.S.C. § 599]16 “effectively established a first priority in payment for the asserted claims of the United States for taxes," if a claimant did not file a proof of claim under the Act, the claimant would not be treated as a creditor under U.S. law. Former Bankruptcy Rule 10-401(b)(3)(A)17 provid*974ed that any creditor, including the United States, whose claim was listed as disputed, contingent, or unliquidated18 as to amount, shall not, with respect to such claim, be treated as a creditor for the purposes of voting and distribution unless such creditor filed a proof of claim prior to approval of the plan. Overseas assumes the IRS would have failed to file a proof of claim in a U.S. bankruptcy proceeding because it failed to file a claim in the Luxembourg court. Based on this reasoning and assumption, Overseas asserts that the IRS should not be considered a creditor of Overseas under U.S. law, and contends the IRS recovered a greater sum in the Luxembourg court than it would have recovered in a U.S. bankruptcy court.
Overseas also argues that, had the IRS filed a proof of claim in a U.S. bankruptcy proceeding, there is no certainty the IRS would have received a greater payment in such a proceeding than it did in the Luxembourg court. A U.S. court might have approved a plan of reorganization similar to the Luxembourg plan and the IRS could have accepted an amount less than its entire claim.
The IRS responds that, under the former Bankruptcy Act, taxes that were not dis-chargeable 19 were entitled to fourth priority in payment, behind actual and necessary bankruptcy administration costs, wages, and expenses of defeating the plan. See 11 U.S.C. § 104(a)(4) (repealed 1978).20 The plan of reorganization, which is attached as an exhibit to Overseas’ complaint, shows that Overseas had assets of $22,578,726 on November 30, 1978. The IRS argues that if, as Overseas concedes, the IRS effectively had first priority to the assets of Overseas, it is plausible the IRS could have recovered from $22.5 million a debt of approximately $1 million.
In order for the court to accept Overseas’ first theory, the court must embrace the assumption that the IRS would not have filed a proof of claim in a U.S. bankruptcy court proceeding. This hypothesis is not borne out by summary judgment evidence and is essential to plaintiff's attempt to circumvent obvious public policy concerns. In fact, it is permissible for the court to infer in favor of the IRS, as the nonmovant,21 that the IRS would have filed a proof of claim, especially where, as here, the IRS aggressively pursued collection ac*975tivities and levied on the proceeds of a subsequent sale involving an Overseas subsidiary. Similarly, in order to credit Overseas’ second argument, the court must assume that the IRS would have received an amount less than 100% of that which it claimed. This premise likewise is unsupported by the summary judgment record; a reasonable inference drawn in favor of the IRS would support the proposition that, out of $22.5 million in assets, the. IRS as a first or even fourth priority claimant could have collected approximately $1 million.
In order to avoid the public policy concerns presented, Overseas was obligated to adduce summary judgment evidence that would establish that the IRS, either as a first or fourth priority claimant, would have received comparable22 treatment under U.S. and Luxembourg law. Because Overseas has failed to carry this burden, the court is unable to hold that recognizing the Luxembourg decree is consonant with U.S. policy.
Accordingly, Overseas’ motion for summary judgment is denied.
SO ORDERED.