Kinnie v. United States, 994 F.2d 279, 286 (6th Cir.1993)). A taxpayer who is not in bankruptcy cannot compel the IRS to allocate payments. Appellant appears to be arguing however, that the bankruptcy court has the authority to compel the IRS to allocate payments to the tax and interest rather than penalty. Appellant’s argument that the IRS’s application of this prepetition payment to the penalty is an avoidable transfer is a back door route to requiring the bankruptcy court to order the IRS to allocate the payment to tax and interest. Several courts, including the Supreme Court, have addressed the issue of the bankruptcy court’s authority to order the IRS to reallocate payments. See United States v. Energy Resources Co., 495 U.S. 545, 549, 110 S.Ct. 2139, 109 L.Ed.2d 580 (1990) (<HOLDING>). But see IRS v. Kaplan Bldg. Sys., Inc. (In re
holding that postconfirmation income that is not necessary to the fulfillment of the plan of reorganization does not become part of the bankruptcy estate holding that postconfirmation income that is not necessary to the fulfillment of the plan of reorganization does not become pari of bankruptcy estate holding that the bankruptcy court has the inherent power to award sanctions for badfaith conduct in a bankruptcy court proceeding holding that creditor lacked appellate standing to appeal order of bankruptcy court absent permission of bankruptcy court holding that a bankruptcy court has the authority to order the irs to apply the payments to trust fund liabilities if the bankruptcy court determines that this designation is necessary to the success of a reorganization plan