The bankruptcy court previously approved an agreement between debtor and the IRS that allowed debtor to use prepetition cash collateral subject to the IRS's secured interest, by granting the IRS a replacement lien in debtor's postpetition cash collateral. In addition, the agreement required debtor to make monthly adequate protection payments to the IRS. Based on debtor's failure to make the agreed adequate protection payments, the IRS requested superpriority of its claim under 11 U.S.C. § 507(b). The court noted that successful reorganization in bankruptcy requires the cooperation of secured creditors, and that adequate protection payments provide a means for debtors to obtain such cooperation. Therefore, when a creditor sacrifices its collateral for the benefit of all, and the adequate protection given to encourage creditor to do so fails, § 507(b) places that creditor's claim ahead of even administrative expenses, deeming it a "superpriority." Calling a cooperative creditor "the catalyst that [more often than not] advances the reorganization effort," the court concluded that there was no equitable justification for denying superpriority to the IRS for the risk it had taken, and superpriority status was granted.