OPINION
WILLIAM V. ALTENBERGER, Bankruptcy Judge.
The Debtor invested as a limited partner in a tax shelter with Philatelic Leasing, Ltd., a limited partnership ("PHILATELIC"). After he filed his personal income tax returns for the years 1979 through 1984, the Internal Revenue Service ("IRS") audited PHILATELIC which resulted in a Tax Court decision in U.S. v. Philatelic Leasing, Ltd.,
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