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IN RE R & L REFUNDS, INC.

Bankruptcy No. 1-84-00243, Adv. No. 1-84-0034.

96 B.R. 105 (1988)

In re R & L REFUNDS, INC., Debtor. R & L REFUNDS, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States Bankruptcy Court, W.D. Kentucky.

October 18, 1988.

Attorney(s) appearing for the Case

Lee L. Coleman, Hughes & Coleman, Bowling Green, Ky., for plaintiff.

Michael F. Spalding, Asst. U.S. Atty., Louisville, Ky., Michael J. Salem, Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

Ray B. White, Bowling Green, Ky., Trustee.

MEMORANDUM OPINION

J. WENDELL ROBERTS, Bankruptcy Judge.

This Adversary Proceeding is before the Court on the parties' cross-motions for Summary Judgment pursuant to Fed.R.Civ. Pro. 56 and Fed.R.Bankr.Pro. 7056. Briefs in support of the parties' respective positions have been filed and reviewed. For the reasons set forth below, we overrule the Plaintiff's Motion for Summary Judgment and sustain the Defendant's Motion for Summary Judgment.

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