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IN RE LOWRIE

Bankruptcy No. BK-S-88-01868-RCJ. Adv. No. 93-2127.

162 B.R. 864 (1994)

In re Mary Lee LOWRIE, Debtor. Mary Lee LOWRIE, Plaintiff, v. UNITED STATES of America (INTERNAL REVENUE SERVICE), Defendant.

United States Bankruptcy Court, D. Nevada.

January 7, 1994.

Attorney(s) appearing for the Case

Timothy S. Cory, Las Vegas, NV, for debtor/plaintiff.

J. Scott Moede, Tax Div., U.S. Dept. of Justice, Washington, DC, for IRS.

MEMORANDUM DECISION RE: CROSS MOTIONS FOR SUMMARY JUDGMENT

ROBERT CLIVE JONES, Chief Judge.

FACTUAL BACKGROUND

The debtor, Mary Lowrie, failed to file tax returns for tax years 1980 and 1981. In 1984, Lowrie and her attorney met with an Internal Revenue Service ("IRS") agent who prepared substitute 1040 forms, and 1902-B and 3547 forms. The substitute 1040's contained only Lowrie's name, address and social security number; the other...

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