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IN RE BROWN

Bankruptcy No. 88-2538-BM, Adv. No. 90-0528-BM.

130 B.R. 456 (1991)

In re Gary Ray BROWN, Debtor. Gary Ray BROWN, Plaintiff, v. UNITED STATES of America, INTERNAL REVENUE SERVICE, Defendant.

United States Bankruptcy Court, W.D. Pennsylvania.

August 5, 1991.

Attorney(s) appearing for the Case

Donald R. Calaiaro, Calaiaro & Corbett, P.C., Pittsburgh, Pa., for plaintiff/debtor.

Joseph F. Minni, Charles M. Flesch, U.S. Dept. of Justice, Washington, Pa.

MEMORANDUM OPINION

BERNARD MARKOVITZ, Bankruptcy Judge.

Plaintiff Gary Ray Brown (hereinafter "debtor") seeks a determination that he owes no debt to the United States of America, Internal Revenue Service (hereinafter "IRS") as a responsible officer of Hermitage W.H. Family Restaurant, Inc. (hereinafter "Hermitage") for unpaid employee federal withholding taxes. He denies that he was a responsible person with respect to Hermitage for purposes of 26 U.S.C...

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