MEMORANDUM OF OPINION
JOHN F. RAY, Jr., Bankruptcy Judge.
This matter is before the Court on the objection of debtor, William Lawrence Summers, to the claim of the United States of America, Internal Revenue Service, the evidence and briefs of counsel.
The issue for decision by the Court is whether the debtor is liable to the United States of America for a 100 percent penalty in the amount of $28,741.96. The United States asserts this claim against...
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