MEMORANDUM OPINION AND ORDER
KENT LINDQUIST, Chief Judge.
I
Statement of Proceedings and Background
This Adversary Proceeding is before the Court on a Motion filed on October 27, 1992 by the United States of America on behalf of its Agency the Internal Revenue Service (hereinafter: "IRS") to Alter Judgment or for New Trial (hereinafter: "Motion"). The Motion of the IRS is directed to the Court's Findings of Fact,...
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