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IN RE BERNARD

Bankruptcy No. 90BK-50223-07, Adv. No. 90AP-5018.

130 B.R. 740 (1991)

In re Jory BERNARD, Cynthia D. Bernard, Debtors. Jory BERNARD, Cynthia D. Bernard, Plaintiffs, v. INTERNAL REVENUE SERVICE, Defendant.

United States Bankruptcy Court, W.D. Louisiana, Lafayette-Opelousas Division.

July 15, 1991.

Attorney(s) appearing for the Case

Ted Hoyt, Lafayette, La., for plaintiffs.

John Bilheimer, Neal Fowler, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant.

MEMORANDUM OPINION

W. DONALD BOE, Jr., Bankruptcy Judge.

Introduction and Summary

This is an action brought by debtor Jory Bernard challenging assessment against him of approximately $180,000 in penalty tax provided by 26 U.S.C. Secs. 6671-6672. He does not dispute the nondischargeability in bankruptcy of the taxes remaining unpaid if he is in fact liable for them.1 Amounts paid by him after assessment total $50...

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