MEMORANDUM DECISION AND ORDER
There are two issues in this case. First, should interest sought by a claimant be allowed on administrative trade and tax claims incurred by a debtor in possession during a chapter 11 case? Second, if allowed, should the interest claims be paid at the same priority as the underlying claims after the chapter 11 case is converted to a case under chapter 7? This Court concludes that interest accrued on certain administrative claims during the chapter 11 ease up until the date the case is converted to chapter 7 should be allowed, and that the interest portion of the claims has the same priority as the underlying claims.
UNDISPUTED FACTS
Rocky Mountain Refractories (Debtor) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code on April 4, 1994. After incurring in excess of $350,-000 in unpaid administrative claims,1 the Court converted the chapter 11 case to a chapter 7 case on September 29, 1995. Stephen W. Rupp was appointed as the Chapter 7 trustee (Trustee). Pursuant to the Trustee’s request, the Court fixed May 1, 1996 as the bar date to file requests for payment of administrative expense claims.
The Tax Claims
The following governmental entities (collectively, the Tax Claimants) filed proofs of *309claim against the Debtor’s estate which the Court deems to be requests for payment of administrative expense claims pursuant to section 503(a) of the Bankruptcy Code:2
Claimant Claim No. Date Filed Tax & Penalties Interest
Salt Lake County Assessor 3 65 Sept. 14,1995 $ 2,596.10 $ 305.00
Internal Revenue Service 68 Jan. 10,1996 $71,692.86 $8,362.50
Utah State Tax Commission 106 April 29,1996 $29,030.84 $1,430.43
Utah Department of Employment Security 111 May 30,1996 4 $ 8,032.03 $ 929.29
The Tax Claimants assert that their respective administrative expense claims (collectively, the Tax Claims) bear statutory interest at the following rates:5 Salt Lake County Assessor (SLCA) at 11)4% per an-num; Internal Revenue Service (IRS) at the variable rate set forth in 26 U.S.C. § 6621; and Utah Department of Employment Security (UDES) at 1% per month. The SLCA, IRS, UDES and, presumably, the Utah State Tax Commission (USTC), also maintain that interest accrues from the date that their respective Tax Claims were incurred during the chapter 11 case, through conversion, until paid by the Trustee in the chapter 7 case.
The Trustee objected to the Tax Claims arguing that the interest asserted in each claim should not be allowed as a first priority claim under sections 507(a) and 723(a)(1), but rather should be allowed priority under section 726(a)(5). By affording the Tax Claimants’ interest claims priority under section 726(a)(5), they would effectively be paid as a fourteenth priority claim, because claims afforded priority under section 507(a), section 726(a)(2)-(4) and chapter 7 administrative expense claims would be paid prior to the interest claims. See 11 U.S.C. §§ 507(a) & 726(a)-(b). The IRS and SLCA filed written responses to the Trustee’s objection, and the IRS, SLCA and UDES appeared at the hearing on the objection held on July 29, 1996. The Tax Claimants assert that, pursuant to decisions of the United States Courts of Appeals for the Fourth, Sixth, Ninth and Eleventh Circuits, interest on administrative expense claims should be allowed and paid according to the same priority as the underlying claim. See Varsity Carpet Serv., Inc. v. Richardson (In re Colortex Indus., Inc.), 19 F.3d 1371 (11th Cir.1994); United States v. Flo-Lizer, Inc. (In re Flo-Lizer, Inc.), 916 F.2d 363 (6th Cir.1990); United States v. Ledlin (In re Mark Anthony Const., Inc.), 886 F.2d 1101 (9th Cir.1989); United States v. Cranshaw (In re Allied Mechanical Sers., Inc.), 885 F.2d 837 (11th Cir.1989); United States v. Friendship College, Inc. (In re Friendship College, Inc.), 737 F.2d 430 (4th Cir.1984); see also Small Business Admin. v. Preferred Door Co. (In re Preferred Door Co.), 990 F.2d 547 (10th Cir.1993) (acknowledging rules established in above cases); Fullmer v. United States (In re Fullmer), 962 F.2d 1463, 1467 n. 4 (10th Cir.1992) (same).
The Trade Claim
On February 6, 1996, Jerry W. Brailsford, a trade creditor of the Debtor, filed a proof of claim which was designated as claim number 88 (Trade Claim). On its face, the Trade Claim seeks payment of $17,504.38 as an unsecured nonpriority claim for goods sold during 1994 and 1995. The documents attached to the Trade Claim demonstrate that *310it is for goods sold to the Debtor prior to and during thé Debtor’s chapter 11 case, plus interest on unpaid amounts for goods sold to the Debtor during the Debtor’s chapter 11 case.
The Trustee objected to the Trade Claim asserting that it should be reclassified into a pre and postpetition claim, and that $1,062.88, constituting the stipulated amount of interest on the postpetition portion of the claim, should be afforded priority under section 726(a)(5) (Interest Trade Claim). The rate used to determine the amount of interest is not stated in the Trade Claim or in the Trustee’s objection, but presumably accrues at a contract or state statutory rate. At a hearing held on July 29, 1996, the Court sustained the Trustee’s objection in part, reclassifying the Trade Claim, but reserving judgment on the allowance of and priority to be afforded to the Interest Trade Claim.
The Court took the Trustee’s objection to the Tax Claims and Interest Trade Claim under advisement. The Court has jurisdiction to issue a final order in this matter pursuant to 28 U.S.C. §§ 157 and 1334, and this matter is a core proceeding under 28 U.S.C. § 157(b)(2)(B). The Court has now considered the memoranda and arguments of counsel and made an independent review of applicable law. Based thereon, the Court concludes that the interest incurred during this chapter 11 case on these administrative expense claims is allowable, but that such interest stopped accruing when the case was converted to a ease under chapter 7, and that the interest incurred during the chapter 11 case must be paid at the same priority as the underlying administrative expense claims.6
ANALYSIS
The Tax and Trade Claims Are Entitled To Interest Until Conversion Of The Case
Since the resolution of the issues in this case requires analysis of an involved network of Bankruptcy Code provisions, the place to begin is with the language of the statute. United States v. Ron Pair Enter., Inc., 489 U.S. 235, 242, 109 S.Ct. 1026, 1030-31, 103 L.Ed.2d 290 (1989). In this case, the Tax Claims and the Trade Claim assert administrative expense claims. Section 503(b), which governs the allowance of administrative expenses, states, in relevant part, that:
(b) After notice and a hearing, there shall be allowed administrative expenses ... including—
(1)(A) the actual, necessary costs and expenses of preserving the estate, including wages, salaries, or commissions for services rendered after the commencement of the case;
(B) any tax—
(i) incurred by the estate ... and
(C) any fine, penalty or reduction in credit relating to a tax of a kind specified in subparagraph (B) of this paragraph. ...
11 U.S.C. § 503(b)(l)(A)-(C). Section 507(a)(1) provides that administrative expense claims allowed under section 503(b) are afforded first priority of payment. 11 U.S.C. § 507(a)(1).7
There is no provision in section 503(b) or any other section of the Bankruptcy Code that governs the allowance of interest on administrative expense claims incurred in a *311chapter 11 case. See In re John Clay & Co., 43 B.R. 797, 812 (Bankr.D.Utah 1984) (recognizing this point); compare section 502(b)(2) (disallowing claims for unmatured, or postpe-tition, interest on prepetition claims). The allowance of interest on administrative expense claims should not be read summarily into the statute especially in light of the well-known principle that administrative expense priority is to be “narrowly construed ‘[because the presumption in bankruptcy cases is that the debtor’s limited resources will be equally distributed among ... creditors.’ ” Isaac v. Temex Energy, Inc. (In re Amaren, Inc.), 853 F.2d 1526, 1530 (10th Cir.1988) (quoting Trustees of Amalgamated Ins. Fund v. McFarlin’s, 789 F.2d 98, 100 (2d Cir.1986)); see Begier v. Internal Rev. Serv., 496 U.S. 53, 58, 110 S.Ct. 2258, 2262, 110 L.Ed.2d 46 (1990) (“Equality of distribution among creditors is a central policy of the Bankruptcy Code.”); General American Trans. Corp. v. Martin (In re Mid Region Petroleum, Inc.), 1 F.3d 1130, 1134 (10th Cir.1993) (administrative expense priorities should fit within the categories listed in section 503(b)). This narrow reading of section 503(b) is supported by the fact that section 503(b)(1)(B) and (C) expressly classify post-petition taxes and fines, penalties and credit reductions on such taxes as administrative expenses, but do not include interest on such taxes. Resolution of the issue in this ease is not so simple, however, because binding precedent compels the allowance of postpetition interest on chapter 11 administrative expense claims.
In Nicholas v. United States, 384 U.S. 678, 86 S.Ct. 1674, 16 L.Ed.2d 853 (1966), a case decided under the former Bankruptcy Act, the Supreme Court held that interest on postpetition, pre-conversion administrative expenses claims is allowable. In Nicholas, a debtor in possession in a reorganization proceeding withheld federal income taxes and social security taxes from postpetition wages paid to its employees, and collected federal excise taxes on certain postpetition receipts. Thereafter, the case was converted8 to a liquidation proceeding and a trustee was appointed. A little more than a month after the trustee was appointed, the taxes that the debtor in possession withheld came due. The trustee neither paid the taxes nor filed any of the required returns. Approximately four years later, the United States submitted an application claiming as administrative expenses the principal of the taxes due, penalties assessed for the trustee’s failure to file tax returns, and interest that had accumulated and would continue to accumulate on the postpetition taxes and penalties until they were paid. Id. at 680-81, 86 S.Ct. at 1677-78.
The relevant issue before the Court in Nicholas was whether the trustee was liable for interest on the taxes incurred by the debtor in possession. Id. at 679, 86 S.Ct. at 1677. The Court held that “the accumulation of interest on a debt must be suspended once an enterprise enters a period of bankruptcy administration beyond that in which the underlying interest-bearing obligation was incurred.” Id. at 685, 86 S.Ct. at 1680. According to the Court, interest accrued at three different points in the bankruptcy proceeding: the pre-arrangement (prepetition) period,9 the arrangement period (the period of time during which the debtor was debtor in possession), and the liquidating bankruptcy period. “A tax incurred within any one of these three periods would ... be entitled to bear interest against the bankrupt estate until, but not beyond, the close of the period in which it was incurred.” Id. at 686, 86 S.Ct. at 1681. Thus, the accumulation of interest on the prepetition tax debt ceased when the arrangement period commenced, *312and the accumulation of interest on tax debt incurred during the arrangement period ceased when the liquidation period commenced. In Nicholas, the claim for interest sought by the United States was disallowed because the arrangement proceeding terminated before the taxes became payable and, therefore, no interest on the taxes accumulated during that proceeding. Id. at 689-90, 86 S.Ct. at 1682-83. But the ultimate holding based on the facts of the case does not change the Court’s pronouncement of the tenet of law applicable to this ease.
Although Nicholas was decided under the Bankruptcy Act, it remains binding law.10 This Court should not abrogate the clear, long-standing rule set forth in Nicholas especially in light the fact that section 503(b) is similar to the Bankruptcy Act provisions interpreted in Nicholas, 11 the policies related to the allowance of administrative expense claims have not changed under the Bankruptcy Code, and Congress did not express a clear intent to abolish the rule in Nicholas when it enacted the Bankruptcy Code. See Dewsnup v. Timm, 502 U.S. 410, 419, 112 S.Ct. 773, 779, 116 L.Ed.2d 903 (1992) (“When Congress amends the Bankruptcy laws, it does not write ‘on a clean slate.’ ... [T]his Court has been reluctant to accept arguments that would interpret the Code, however vague the particular language under consideration might be, to effect a major change in pre-Code practice that is not the subject of at least some discussion in the legislative history.”) (citations omitted); Ron Pair Enter., 489 U.S. at 245, 109 S.Ct. at 1032-33 (judicially created concepts should be retained if a statutory provision is ambiguous, prior law reflected significant policy considerations of great longevity and importance, and a proposed interpretation is in clear conflict with state or federal laws of great importance); Kelly v. Robinson, 479 U.S. 36, 47, 107 S.Ct. 353, 359-60, 93 L.Ed.2d 216 (1986) (silent abrogation of judicially created concepts is particularly disfavored when construing the Bankruptcy Code); Midlantic Natl. Bank v. New Jersey Dept. of Environmental Protection, 474 U.S. 494, 501, 106 S.Ct. 755, 759, 88 L.Ed.2d 859 (1986) (“The normal rule of statutory construction is that if Congress intends for legislation to change the interpretation of a judicially created concept, it makes that intent specific.... The Court has followed this rule with particular care in construing the scope of bankruptcy codifications.”) (citation omitted); Colortex, 19 F.3d at 1375 & 1378 (recognizing this rule of statutory construction in the context of analyzing the vitality of Nicholas); Allied Mech. Servs., 885 F.2d at 839 (absent clear indication from Congress existing law under Nicholas should not be altered). Although Nicholas involved postpetition interest on tax claims, it is not limited to the allowance of interest on tax claims and, therefore, applies to trade' claims as well. Colortex Indus., 19 F.3d at 1382.12
*313The Court recognizes this ruling conflicts with John Clay, 43 B.R. at 812, in which this Court held that chapter 11 administrative expenses claimants were not entitled to interest on their claims because, as recognized above, “there is nothing in the Code to permit payment of interest to those holding an administrative expense claim.” The Court in John Clay did not address Nicholas, and since John Clay the Tenth Circuit has indicated, without directly deciding, that interest on chapter 11 administrative expense claims is allowable. See Preferred Door, 990 F.2d at 547;13 see also Fullmer, 962 F.2d at 1467 n. 4 (debtor conceded that taxing authority could collect interest on taxes arising postpe-tition and that Tenth Circuit recognizes several courts of appeals which have allowed such interest).
By allowing interest on chapter 11 administrative expense claims, this Court is not forsaking the parameters of section 503(b). Section 503(b), by its express terms, is not limiting inasmuch as it states that “there shall be allowed administrative expenses ... including — ” the expenses listed in subsection (b) of that section. 11 U.S.C. § 503(b); see section 102(3) (rules of construction of the Bankruptcy Code state that the word “including” is not limiting).14 The Court has recognized that “[w]hile it is true that the court is not free to fashion additional priorities it ought not be assumed that the six designations [in § 503(b) ] are necessarily exclusive nor designed to cover every conceivable situation.” In re Callister, 15 B.R. 521, 526 n. 20a (Bankr.D.Utah 1981) (quoting 3 Collier on Bankruptcy, ¶ 503.03 at 503-11-12 (15th ed. 1981)).15 Construing section 503(b) to allow interest to accrue on chapter 11 administrative expense claims up until the time a case is converted to chapter 7 also facilitates its general purpose of encouraging creditors to continue dealing with and extending credit to a chapter 11 debtor in order to aid the debtor’s reorganization. Mid Region Petroleum, 1 F.3d at 1134; see Nicholas, 384 U.S. at 687, 86 S.Ct. at 1681-82 (allowance of interest on postpetition debts promotes the availability of capital to the debtor and enhances the likelihood of achieving the goal of rehabilitation).
It is undisputed that the Tax Claims and the Trade Claim became payable prior to the conversion of the Debtor’s case from chapter 11 to chapter 7. Applying Nicholas, interest that accrued on the Tax Claims and the Trade Claim during the postpetition, pre-conversion period is allowable.16 Once the Court decides that interest accrued on chapter 11 administrative expense claims prior to conversion constitute allowable claims, the remaining issue is what priority the interest *314on the Tax Claims and the Trade Claim is to be afforded in light of the conversion of the Debtor’s case to one under chapter 7 of the Bankruptcy Code.
Allowed Interest Is Entitled To The Same Priority As Underlying Claims
In Nicholas, the Supreme Court stated that:
[T]axes incurred during the arrangement period are expenses of the Chapter XI proceeding and are therefore technically a part of the first priority under § 64a(l). The final sentence of that section, however, subordinates arrangement expenses within that priority to the expenses of the superseding bankruptcy administration. Tax claims incurred during Chapter XI proceedings are therefore in fact junior to claims for expenses incurred in subsequent bankruptcy proceedings. The suspension of interest on taxes incurred during the arrangement period as of the date a bankruptcy petition is filed thus corresponds to the suspension of interest on pre-arrangement taxes when a Chapter XI petition is filed.
384 U.S. at 687-88, 86 S.Ct. at 1682 (footnote omitted). Nicholas dictates that interest on the Tax Claims and the Trade Claim be paid in the same priority as the underlying claims — as administrative expense claims in the chapter 11 case. Finding that interest on administrative expense claims is payable as an administrative expense of the chapter 11 case is in accord with all of the decisions of the United States Courts of Appeals which have addressed this issue.17 The decisions of the Courts of Appeals have been cited with approval by the Tenth Circuit in Preferred Door, where the Court assumed that interest on administrative expense claims is allowable and paid at the same priority as the underlying claim. 990 F.2d at 547; see also Fullmer, 962 F.2d at 1467 n. 4 (in dicta Tenth Circuit, citing Mark Anthony and Allied Mechanical Servs., acknowledges that interest on administrative expense claims may be allowable).
The Trustee argues that this result cannot occur because it conflicts with section 726 *315which governs distribution in chapter 7 cases. Section 726 states, in relevant part, that:
(a) Except as provided in section 510 of this title, property of the estate shall be distributed—
(1) first, in payment of claims of the kind specified in, and in the order specified in, section 507 of this title ...;
(5) fifth, in payment of interest at the legal rate from the date of the filing of the petition, on any claim paid under paragraph (1), (2), (3), or (4) of this subsection....
11 U.S.C. § 726(a)(1) & (5).
Under this section, the trustee is required to distribute property of the estate in a champagne waterfall fashion. The trustee is first required to make distributions to claimants in the order specified in section 507. This means that administrative expense claims allowed under section 503(b) are afforded first priority, subject to the limitations on chapter 11 administrative expense claims which are subordinated to chapter 7 administrative expense claims under section 726(b). 11 U.S.C. §§ 503(b), 507(a) & 726(a)(1) & (b). After the trustee pays claims in the order set forth in section 507, the trustee pays the claims described in subsections (a)(2) through (4) of section 726. Only after all claims, both timely and tardily filed, and fines and penalties are paid, is the trustee authorized to pay interest on paid claims under section 726(a)(5). Any estate property left after the payment of interest is paid to the debtor. 11 U.S.C. § 726(a)(6).
According to the Trustee, section 726(a)(5), the only section of the Bankruptcy Code related to priority of distribution that discusses interest, requires that interest on chapter 11 administrative expense claims be paid pursuant to section 726(a)(5), which is actually a fourteenth priority, rather than as a first priority claim under sections 503(b), 507(a) and 726(a)(1). Any other reading the Trustee maintains would render section 726(a)(5) meaningless.18
The Trustee’s argument has appeal,19 but must be rejected because section 726(a)(5) can be read in conjunction with Nicholas without being rendered meaningless. Under Nicholas, interest on the administrative expense claims incurred during the chapter 11 case is an integral part of that claim. Nicholas, 384 U.S. at 678, 86 S.Ct. at 1674; see also Bruning, 376 U.S. at 360, 84 S.Ct. at 908 (“interest is ... an integral part of a continuing debt.”); Allied Mech. Servs., 885 F.2d at 839 (recognizing this point). Therefore, the administrative expense claim, including interest incurred during the chapter 11 case, is paid as the “claim” under section 726(a)(1). Under section 726(a)(5), after the entire administrative expense claim including interest accrued during the chapter *31611 case is paid pursuant to sections 507(a)(1) and 726(a)(1) and (b), and all other claims listed in subsections (a)(1) through (4) of section 726 are paid in full, any remaining funds may be used to pay interest on all of the claims, including claims which contain interest.20
Stated another way, if a debtor is solvent, section 726(a)(5) requires the payment of interest on interest. Unpaid chapter 11 administrative expense claimants may assert a claim against the chapter 7 estate which includes interest incurred during the chapter 11 case. This claim must be paid in full as a first priority claim under sections 507(a) and 726(a)(1), subject only to chapter 7 administrative expense claims which are afforded superpriority under section 726(b). If the debtor proves to be solvent, the claimant is entitled to interest on its entire claim under section 726(a)(5), including that portion of its claim for interest incurred during the chapter 11 ease, prior to return of any property to the debtor.
This interpretation is consistent with the history of section 726(a)(5) which was enacted to codify the “solvent debtor rule.” This rule provides that if “the debtor proves solvent, a balance of the equities dictates that creditors may receive any surplus, including claims for interest arising postpetition, ahead of payment to the debtor.” Colortex, 19 F.3d at 1376 (citing Saper, 336 U.S. at 332 n. 7, 69 S.Ct. at 556 n. 7; Sexton, 219 U.S. at 344, 31 S.Ct. at 257); see American Iron & Steel Mfg. Co. v. Seaboard Air Line Ry., 233 U.S. 261, 267, 34 S.Ct. 502, 504-05, 58 L.Ed. 949 (1914). The solvent debtor rule existed well before the Supreme Court’s ruling in Nicholas and, therefore, creditors who extended goods or services to a debtor in a reorganization proceeding under the Bankruptcy Act presumably were afforded interest on interest.
The Court’s interpretation of section 726(a)(5) is also consistent with the treatment of prepetition unsecured creditors who are entitled to interest on unpaid debts up until the date a bankruptcy petition is filed. 11 U.S.C. § 502(b)(2); see Nicholas, 384 U.S. at 682, 86 S.Ct. at 1678-79 (citing Sexton, 219 U.S. at 339, 31 S.Ct. at 257); Saper, 336 U.S. at 328, 69 S.Ct. at 555. Interest accrued prepetition becomes part of these creditors’ claims. See In re Bates, 974 F.2d 1234 (10th Cir.1992) (prepetition interest on tax debt had same priority as the tax). If there are sufficient funds to make a distribution under section 726(a)(5), the creditors receive payment of their claim in full, including prepetition interest, plus interest accruing on the entire claim at the legal rate from the petition date. See S.Rep. No. 989, 95th Cong., 2d Sess. 96-97 (1978) (the Senate Report accompanying section 726(a)(5) recognized that this section “also specifies that interest accrued on all claims (including priority and nonpriority tax claims) whieh accrued before the date of the filing of the title 11 petition is to be paid in the same order of distribution of the estate’s assets as the principal amount of the related claims.”) Since prepetition creditors are entitled to interest on interest if a debtor is solvent, it is fair to allow the same to administrative expense claimants who have provided services or goods to a chapter 11 debtor and were not paid prior to conversion.
Finally, the Court’s interpretation of section 726(a)(5) prevents the stripping of a chapter 11 claimant’s priority claim by mere happenstance of conversion of a case to chapter 7. There is no provision in chapter 11 similar to section 726(a)(5) which could be read to prevent the payment of interest on *317administrative expense claims. Thus, under Nicholas and section 1129(a)(9), chapter 11 administrative expense claimants could expect to be paid cash on the effective date of a plan for the entire amount of their claims, including interest that had accrued on unpaid portions of their claims. If the case were converted to chapter 7, however, and the Trustee’s argument were to be adopted, the same claimants, asserting the same claims, would have the interest portion of their claims stripped. Nothing in the Bankruptcy Code warrants such a result,21 and disallowing such claims would deter creditors from dealing with chapter 11 debtors.
CONCLUSION
Accordingly, the Court concludes that interest requested on the Tax Claims and on the Trade Claim incurred during this chapter 11 ease should be allowed, but that interest stops accruing on the date that the case was converted to chapter 7. In addition, that portion of the claim for interest has the same priority as the underlying claims.
ORDER
Based on the foregoing, it is hereby
ORDERED, that:
(1) The Trustee’s objection to the Tax Claims is overruled; and
(2) The Trustee’s objection to the Interest Trade Claim is overruled.