MEMORANDUM OPINION AND ORDER
BENJAMIN E. FRANKLIN, Chief Judge.
This matter comes on before the Court pursuant to the December 3 and 4, 1991 trial on the complaint of Roberts Metal Fabrication, Inc. (hereinafter "debtor") seeking abatement of tax penalties pursuant to 11 U.S.C. § 505(a). The debtor appeared by and through its attorney, John H. Trader and local counsel, Joe Vise. The United States of America appeared by and through its attorney, James...
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