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IN RE GRAHAM

Bankruptcy No. 87-03092F, Adv. No. 88-0630F.

108 B.R. 498 (1989)

In re Thomas A. GRAHAM and Elizabeth M. Graham, Debtors. Thomas A. GRAHAM and Elizabeth M. Graham, Plaintiffs, v. INTERNAL REVENUE SERVICE, Defendant.

United States Bankruptcy Court, E.D. Pennsylvania.

December 14, 1989.

Attorney(s) appearing for the Case

Spencer Ervin, Jr., Leslie Beth Baskin, Gratz, Tate, Spiegel, Ervin & Ruthrauff, Philadelphia, Pa., for the debtors/plaintiffs, Thomas A. Graham and Elizabeth M. Graham.

Stuart Glick, Dept. of Justice, Washington, D.C., H. Stephen Kesselman, District Counsel, I.R.S., Philadelphia, Pa., for defendant I.R.S.

James J. O'Connell, Asst. U.S. Trustee, Philadelphia, Pa.

Christine C. Shubert, Tabernacle, N.J., trustee.

MEMORANDUM OPINION

BRUCE I. FOX, Bankruptcy Judge:

The debtors have brought an adversary proceeding against the Internal Revenue Service ("IRS"), seeking a determination of the dischargeability through bankruptcy of certain tax liabilities under 11 U.S.C. § 523(a)(1)(C). While the IRS initially challenged nondischargeability for these liabilities against both debtors, at the trial on the matter it agreed that taxes for the years 1969 through 1972 were...

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