ORDER GRANTING THE UNITED STATES MOTION FOR SUMMARY JUDGMENT
MARY D. SCOTT, Bankruptcy Judge.
THIS CAUSE is before the Court upon the cross-motions for summary judgment filed by the parties. The United States filed the response to the debtors' cross-motion for summary judgment on January 14, 1994, at which time the matter was under submission. The debtors initiated this adversary proceeding on June 15, 1993, seeking a determination that federal income...
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