MEMORANDUM OF DECISION AND ORDER
PFAELZER, District Judge.
This appeal concerns whether a tax fraud penalty assessed by the Internal Revenue Service ("IRS") against the debtors Alton Vaughn Byrum and Juanita Doris Byrum ("the Byrums") is dischargeable under Chapter 7 pursuant to section 523(a)(7)(B) of the Bankruptcy Code. 11 U.S.C. § 523(a)(7)(B). Bankruptcy Court Judge John E. Ryan held that the debt was dischargeable. In reaching this determination...
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