MEMORANDUM AND ORDER
ROSENTHAL, District Judge.
Pending before this court are the briefs of appellant United States of America ("appellant") and appellee Thomas Allan Lile ("appellee"). After a careful review of the facts, the parties' submissions, and the applicable authority, this court AFFIRMS the bankruptcy court's decision.
This case arises out of efforts by the Internal Revenue Service ("IRS") to collect payroll...
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