MEMORANDUM AND ORDER
HUYETT, District Judge.
This is an appeal from a final order of the bankruptcy court dated December 14, 1989, determining that the federal tax liabilities of the debtors, Thomas and Elizabeth Graham, were dischargeable. This court has jurisdiction to hear this appeal pursuant to 28 U.S.C. § 158(a) and Bankruptcy Rule 8001(a).
This appeal presents three issues. The first issue is whether debtor Thomas A. Graham
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