MEMORANDUM OPINION
WILLIAM T. BODOH, Bankruptcy Judge.
This cause is before the Court on competing Motions for Summary Judgment filed by Plaintiff/Debtors, FREDERICK and CAROL LONGLEY ("Debtors"), and by Defendant, UNITED STATES OF AMERICA, INTERNAL REVENUE SERVICE ("the Government"), in the above-captioned adversary proceeding. For the reasons set forth below, the Court grants summary judgment in favor of the Government.
FACTS
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