OPINION AND ORDER
JOHN W. POTTER, Senior District Judge:
This action is before the Court on appellant's appeal from the bankruptcy court's order discharging appellees' 1981 and 1983 income tax liabilities pursuant to 11 U.S.C. § 523(a)(1)(A).
On November 27, 1991, appellees filed a petition in bankruptcy court under Chapter 7 of Title 11. Prior to the petition, appellees made a formal written offer in compromise of their federal tax liability...
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