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IN RE AMICI

Bankruptcy No. 88-6465-9P7. Adv. No. 92-831.

177 B.R. 386 (1994)

In re Mario AMICI, Debtor. Mario AMICI, Plaintiff, v. UNITED STATES of America, Defendant.

United States Bankruptcy Court, M.D. Florida, Tampa Division.

November 25, 1994.

Attorney(s) appearing for the Case

Francis H. Cobb, Tampa, FL, for debtor/plaintiff.

Philip A. Doyle, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, DC, for defendant.

FINDINGS OF FACT, CONCLUSIONS OF LAW AND MEMORANDUM OPINION

ALEXANDER L. PASKAY, Chief Judge.

THIS IS a Chapter 7 liquidation case and the matter under consideration is a Complaint filed by Mario Amici (Debtor) seeking a determination that two penalties assessed against the Debtor by the Internal Revenue Service (IRS) are dischargeable. The Debtor also requests injunctive relief against the IRS. The Complaint contains two counts. The claim in Count I involves...

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