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IN RE FOX

Bankruptcy No. 94-30243. Adv. No. 94-3072.

172 B.R. 247 (1994)

In re Randal Charles FOX, Alice Amanda Fox a/k/a Alice A. Kelly, Debtors. Randal Charles FOX, Plaintiff, v. The UNITED STATES of America; INTERNAL REVENUE SERVICE, Defendant.

United States Bankruptcy Court, E.D. Tennessee.

September 20, 1994.

Attorney(s) appearing for the Case

John H. Fowler, Sevierville, TN, for plaintiff.

Carl K. Kirkpatrick, U.S. Atty., Knoxville, TN, Shannon L. Hough, U.S. Dept. of Justice, Tax Div., Washington, DC, for U.S. and its agency, the I.R.S.

MEMORANDUM ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

RICHARD S. STAIR, Jr., Bankruptcy Judge.

The debtor, Randal Charles Fox, commenced this adversary proceeding by filing a Complaint on June 17, 1994, seeking a determination of the dischargeability of his federal income tax liabilities for 1985 and 1986.1 The Internal Revenue Service (IRS) responded on July 25, 1994, with a motion entitled "Motion to Dismiss for Failure...

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