ORDER GRANTING MOTION FOR SUMMARY JUDGMENT
BLACKWELL N. SHELLEY, Bankruptcy Judge.
This cause comes on to be considered by motion of defendant, I.R.S., for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure, and by memoranda of the I.R.S. filed May 4, 1987 and June 1, 1987 in support of the motion, and by memoranda of plaintiffs, Dewey Lee Franklin and Shirley Franklin, of counsel, filed May 8, 1987 and June 11, 1987 in opposition...
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