MEMORANDUM OPINION
JOSEPH C. ELLIOTT, Chief Judge.
This matter arises upon the Motion to Determine Tax Liability filed on behalf of the Trustee in this case. The issue presented is whether the estate of the Debtors, who are individuals and not corporations, is subject to federal income tax for the years 1980-1983, inclusive. The parties, who are the Trustee and the Internal Revenue Service, have agreed that the facts are not in dispute and that the question...
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