MEMORANDUM OPINION
WILLIAM T. BODOH, Bankruptcy Judge.
This cause is before the Court on the Motion of Debtors to dismiss the above-captioned adversary proceeding or, in the alternative, for summary judgment on the issues presented herein. Plaintiff, THE UNITED STATES OF AMERICA, INTERNAL REVENUE SERVICE ("IRS"), has opposed the Motions. Briefs have been filed by both parties.
The parties do not dispute the factual background of this case. Debtors...
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