MEMORANDUM OPINION
WILLIAM M. TAYLOR, Jr., District Judge.
Plaintiff Robert Henry Severance filed this appeal challenging the actions of the bankruptcy court in granting the government's motion for summary judgment to the effect that certain tax penalties assessed against Plaintiff are non-dischargeable. Upon consideration of the record on appeal, briefs filed by Plaintiff and the government, and oral arguments of counsel, we are of opinion for the reasons...
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