OPINION & ORDER
BERTELSMAN, Chief Judge.
I. INTRODUCTION
This is a bankruptcy appeal, pursuant to 28 U.S.C. § 158(a). This case is before the court on the appeal of the Internal Revenue Service (IRS) and the cross-appeal of Thomas Mando.
II. FACTUAL BACKGROUND
Appellee, Thomas Mando, is a trained optician, and was a stockholder of Tru-Site Laboratories, Inc. (Tru-Site), a Kentucky corporation. From its inception...
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