AMENDED MEMORANDUM OPINION
ROBERT McGUIRE, Chief Judge.
This matter came before the Court on cross motions for summary judgment filed on behalf of Robert H. Hopkins, Jr. ("Plaintiff") and United States of America (Internal Revenue Service) ("IRS" or "Defendant"). On August 22, 1990, Plaintiff filed a complaint to determine the dischargeability of certain income tax penalties and interest asserted in a June 4, 1990, IRS statutory notice of deficiency (the...
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