MEMORANDUM OPINION
STEPHEN J. COVEY, Bankruptcy Judge.
This matter comes on to be heard upon the Cross-Motions for Summary Judgment filed by Donald P. Taylor ("Debtor") and the United States of America ex rel. the Internal Revenue Service ("IRS"). Summary judgment is proper when there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Celotex Corp. v. Catrett,
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