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IN RE BURNS

No. 89-8127.

887 F.2d 1541 (1989)

In Re Joanne G. BURNS, Debtor. Joanne G. BURNS, Plaintiff-Appellee, v. UNITED STATES of America, Acting by and Through the INTERNAL REVENUE SERVICE, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

November 13, 1989.

Attorney(s) appearing for the Case

Gary R. Allen, Chief, Appellate Section, U.S. Dept. of Justice, Tax Div., Kevin M. Brown, Gary D. Gray, Washington, D.C., for defendant-appellant.

Richard A. Childs, Columbus, Ga., for plaintiff-appellee.

Before JOHNSON, Circuit Judge, RONEY, Senior Circuit Judge, and MELTON, District Judge.

MELTON, District Judge:

Joanne G. Burns, the Debtor, initiated an adversary proceeding in the bankruptcy court to determine the priority status, amount and dischargeability of her federal income tax liabilities for the years 1977 through 1981, 1983 and 1985, together with penalties assessed thereon and accrued interest, for which the Internal Revenue Service ("IRS") had filed a claim in her Chapter 13 case. The parties resolved many

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