Well the IRS is #1 on the Priority Secured list at over $700,000, they might settle for $100,000. See below for the total SECURED and PRIORITY claims (over $9,000,000) so if they take 5% settlement thats still $450,000. The shell is worth $150,000 max. Not a great business deal in my opinion.
Secured $9830942.70
Priority $999287.19