MEMORANDUM AND ORDER
BILL H. BRISTER, Bankruptcy Judge.
Hannan Trucking, Inc., the debtor-taxpayer, filed this adversary proceeding against the United States of America, challenging the application made by Internal Revenue Service of payments of delinquent taxes by the taxpayer. Nonjury trial was conducted on September 29, 1981. This factual summary constitutes the findings required by Rule 752.
The principal stockholder and officer of the debtor...
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