MEMORANDUM OPINION AND ORDER
ZATKOFF, District Judge.
This matter is before the Court on defendant's motion for reconsideration of a May 3, 1991 Memorandum Opinion and Order denying defendant's motion for summary judgment.
FACTS
The following facts are a brief summary of the May 3, 1991 Opinion. On May 9, 1985, an involuntary bankruptcy proceeding was filed against the THA Corporation. The internal revenue service ("IRS") filed a proof...
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