can rely on an exception to section 1327(a). There are two statutory exceptions to section 1327(a), section 1330(a) and 1307(c), that the IRS can arguably rely upon to contest Debtors’ Chapter 13 plan and eligibility. Section 1330 authorizes the court to revoke a confirmation order if: (1) relief is requested within 180 days of the Confirmation Order; and (2) it is established that the Order was procured by fraud. 11 U.S.C.A. § 1330(a); In re Brown, 76 B.R. 1013, 1015 (Bkrtcy.E.D.Pa.1987). Even if the government could prove section 1330(a)’s exacting fraud standard, see In re Hicks, 79 B.R. 45, 48 (Bkrtcy.N.D.Ala.1987), the IRS would be unable to rely on this statutory provision because greater than six months has passed since the order of confirmation. See In re Brown, 76 B.R. at 1015 (<HOLDING>); Combs v. Combs, 34 B.R. 597, 600
holding suit filed ninetyone days after notice untimely holding that a request made within 180 days of a modified confirmation order  entered three months after the original confirmation order  but more than 180 days after the original confirmation order was timebarred holding  1330a motion not now justiciable because not raised within 180 days of confirmation holding that a private right of action does not arise until 180 days after a charge has been filed holding  1330a motion untimely when filed over 180 days from confirmation