MEMORANDUM GRANTING MOTION FOR SUMMARY JUDGMENT AND DETERMINING TAX LIABILITY
JAMES A. PUSATERI, Bankruptcy Judge.
This matter comes before the Court on the debtors' motion for determination of tax liability and on the United States' motion for summary judgment. Paul and Janet Carter ("Debtors") are represented by Jan Hamilton. The United States ("U.S.") is represented by Charles S. Kennedy, III, Tax Division, U.S. Department of Justice.
FINDINGS...
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