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IN RE TOWE

Bankruptcy No. 90-11695-JLP-7.

147 B.R. 545 (1992)

In re William Edward TOWE, aka Edward Towe and Cora Florence Towe, aka Florence Towe, Debtors. UNITED STATES of America, Plaintiff, v. William Edward TOWE, and Cora Florence Towe, Defendants.

United States Bankruptcy Court, D. Montana, Billings Division.

September 4, 1992.

Attorney(s) appearing for the Case

Kirk C. Lusty, Keith P. Duet, Trial Attorneys, Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff.

Carey E. Natovich, Matovich, Addy & Keller, P.C., Billings, Mont., for defendants.

MEMORANDUM DECISION

ROBERT L. EISEN, Bankruptcy Judge.

I. INTRODUCTION

William Edward Towe and Cora Florence Towe, husband and wife, filed a bankruptcy petition under chapter 7 on November 14, 1990. The I.R.S. previously had audited the debtors for the tax years 1969 through 1982 and had assessed federal income tax liabilities totalling $1,054,307.52. The I.R.S. also assessed penalties and lien fees for the same period totalling $264,517.63, and...

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