MEMORANDUM OPINION
CLIVE W. BARE, Bankruptcy Judge.
The issue before the court in this adversary proceeding is whether the debtor's discharge in bankruptcy also discharges tax penalties relating to nondischargeable tax liabilities incurred more than three years before the filing of the bankruptcy petition. 11 U.S.C. § 523(a)(7).
I
Plaintiff, Marvin Lee Henderson ("Henderson"), timely filed his federal income tax returns for 1982 and...
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