Robert Gambrell, Gambrell & Associates, PLLC, Oxford, MS, for Debtors., Judge Jason D. Woodard, United States Bankruptcy Judge This matter came before the Court for hearing on February 8, 2018, on the Objection to Claim of the Internal Revenue Service (the "Objection")(Dkt. # 110) filed by debtors Dr. David R. Donaldson and Cynthia A. Donaldson. The Donaldsons appeared at the hearing, along with their attorney, Robert Gambrell. Samuel Wright, Assistant United States Attorney, appeared on behalf of the Internal Revenue Service (the "IRS")., In the Objection, the Donaldsons seek a reallocation of funds received prepetition by the IRS that were applied to non-debtor Impact Missions, Inc.'s ("IMI") prepetition tax obligations. The IRS has deemed Dr. Donaldson a "responsible person" who is liable for IMI's failure to pay certain trust fund taxes and assessed a Trust Fund Recovery Penalty ("TFRP") against him. Dr. Donaldson contends that all of the funds received should be applied to these trust fund taxes, rather than split between the trust fund taxes and other taxes for which he has no personal liability. Dr. Donaldson testified at the hearing, as did Brian Redden, former IMI chairman, Wes Edwards, a former IMI board member, and Terry Griffith, IMI's former CPA and consultant. At the conclusion of the hearing, the Court requested additional briefing from the parties. All briefs have now been filed (Dkt. # 160, 161, 163, and 164)., Beginning in 2012, IMI accumulated significant trust fund tax liabilities due to IMI's failure to withhold, file returns, and pay required quarterly trust fund taxes related to employee payroll. The trust fund tax liabilities continued to accrue through 2013 and 2014 due to IMI's continued failure to account for and remit payroll withholding taxes. Dr. Donaldson testified that he first became aware of IMI's trust fund tax delinquency in the first quarter of 2013. Despite Dr. Donaldson's knowledge of the tax arrearage, IMI continued to fail to pay its ongoing trust fund tax obligations. The liabilities at issue are the TFRP assessments issued against Dr. Donaldson for all four quarters of 2013 and the first quarter of 2014, while he was president and CEO of IMI., Dr. Donaldson testified that he believed that the Contingent Assets had sufficient equity to fully pay IMI's past due and accruing tax liabilities. To that end, IMI's former CPA, Terry Griffith, testified that he facilitated a meeting at his office on June 19, 2014, between Cathy Aders, an IRS Revenue Agent, and Dr. Donaldson to discuss the past due taxes and IMI's plans to use the Contingent Assets to pay those taxes. At the meeting, Dr. Donaldson told Ms. Aders that IMI had submitted the BP Claim in 2013 and that IMI intended to use the proceeds of that claim (the "BP Funds"), along with excess proceeds from the sale of the real property, to pay IMI's past due tax obligations. Mr. Griffith testified that IMI intended that the BP Funds be designated as a voluntary payment to the IRS to be used first for the satisfaction of IMI's past due payroll tax obligations. Mr. Griffith further testified that he assisted Dr. Donaldson and the IMI Board in drafting a resolution intended to memorialize the meeting and IMI's plan to pay its past due tax obligations. Dr. Donaldson testified that he was instrumental in passing the resolution and that he specifically included a provision to attempt to direct the application of the BP Funds as a voluntary payment to the IRS. This was an internal IMI document. The IRS was not a party to any agreement to designate the BP Funds in this manner., The Donaldsons filed their chapter 13 bankruptcy petition on November 22, 2016 (Dkt. # 1). The IRS timely filed its proof of claim on May 26, 2017 (Claim # 10) in the amount of $87,564.09, consisting of Dr. Donaldson's TFRP liability for all four quarters of 2013 and the first quarter of 2014. On August 22, 2017, the Donaldsons filed the Objection seeking a reallocation of the BP Funds solely to trust fund taxes for which Dr. Donaldson has TFRP liability. The Donaldsons contend that IMI made a "voluntary payment" designation of the BP Funds, and that, therefore, the IRS should have applied all of the BP Funds to periods for which Dr. Donaldson was assessed a TFRP as a responsible person. The IRS argues that the Donaldsons' Objection should be overruled, first on jurisdictional grounds, but also on substantive grounds.