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IN RE WALTER

No. 3:92 CV 7393.

158 B.R. 984 (1993)

In re Elmer & Dorla WALTER, Debtors. UNITED STATES of America, Appellant, v. John J. HUNTER, Trustee, Appellee.

United States District Court, N.D. Ohio, W.D.

September 30, 1993.

Attorney(s) appearing for the Case

Verne K. Armstrong, Office of the U.S. Atty., Toledo, OH, Stacy Hallett, Tax Div., Dept. of Justice, Washington, DC, for U.S.

Howard A. Elliott, Christopher Law Office, Findlay, OH, for debtors.

John J. Hunter, Jr., Hunter & Schank, Toledo, OH, Trustee.

MEMORANDUM OPINION

DOWD, District Judge.

This action is before the Court on the appeal of the United States, Department of Internal Revenue Service ("IRS") from the June 10, 1992 decision of the United States Bankruptcy Court. This Court's jurisdiction to hear appeals from a judgment, order or decree of a United States Bankruptcy judge is pursuant to 28 U.S.C. § 158(a).

STANDARD OF REVIEW

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