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IN RE ROBIDOUX

Bankruptcy No. 4-80-00378-G, Appeal No. 89-40052-XX.

116 B.R. 320 (1990)

In re Richard ROBIDOUX, Debtor.

United States District Court, D. Massachusetts.

July 30, 1990.

Attorney(s) appearing for the Case

Jay M. Pabian, Bruce W. Edmands, Mahoney, Hawkes & Gouldings, Boston, Mass., for Richard E. Robidoux.

M. Ellen Carpenter, Asst. U.S. Atty., Boston, Mass., Thomas R. Jones, Atty. Tax Div., U.S. Dept. of Justice, Washington, D.C., for U.S.

MEMORANDUM OF DECISION

YOUNG, District Judge.

INTRODUCTION

In 1979, the Internal Revenue Service (the "Service") conducted an audit on the 1977 and 1978 tax returns of Mr. Richard Robidoux ("Robidoux"). Subsequent to completing the audit, the Service prepared an audit report in which it determined that Robidoux owed $2,044,984.06 in past due taxes for these years.1 In 1981...

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