MEMORANDUM DECISION
ROBERT D. MARTIN, Chief Judge.
The facts in this case are not disputed. On April 10, 1991, Gerald T. and Ruth M. Byrne ("debtors") entered into a cash control agreement with the Rock County Bank which restricted the debtors' ability to make payroll tax payments. On October 8, 1991, the debtors filed federal payroll tax form 941 for the third quarter of 1991, enclosed a letter from O'Leary Law...
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