OPINION
DAVID W. HOUSTON, III, Bankruptcy Judge.
On consideration before the court is a motion for summary judgment filed by the Mississippi Department of Revenue, f/k/a Mississippi State Tax Commission, ("MDR"); a response to said motion having been filed by the plaintiffs, Alvin C. Atkinson and Sandra Atkinson, ("debtors"); and the court, having considered same, hereby finds as follows, to-wit:
I.
The court has jurisdiction of the parties...
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