MEMORANDUM ORDER
FISH, District Judge.
Before the court is the appeal of debtor Sharon Freytag ("Ms. Freytag") from an order of the bankruptcy court determining that she is not entitled to relief as an innocent spouse from the claims of the Internal Revenue Service ("IRS"). For the reasons stated below, the order of the bankruptcy court is affirmed.
I. BACKGROUND
Sharon and Thomas Freytag deducted substantial losses on their...
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