MEMORANDUM OPINION AND ORDER
KANE, Senior District Judge.
This is an appeal and cross-appeal from a bankruptcy court ruling holding that the debtors, Gerald and Annette Linder, were not discharged from paying delinquent taxes for tax years 1982, 1983, and 1985, but that penalties for tax year 1985 were dischargeable. The debtors appeal the court's order as to the nondischargeability of the taxes, and the government appeals the order as to the dischargeability...
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