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IN RE SIVERLING

Bankruptcy No. 92-31164-A-13. Motion Control Nos. IRS-1, RD-1.

179 B.R. 909 (1995)

In re William SIVERLING and Linda Siverling, Debtors.

United States Bankruptcy Court, E.D. California, Sacramento Division.

Decided January 11, 1995.

Attorney(s) appearing for the Case

Richard Dangler, Sacramento, CA, for debtors.

Charles J. Stevens, U.S. Atty., John F. Gisla, Asst. U.S. Atty., and Thomas M. Rohall, Lori M. Mersereau, Bruce E. Gardner, Sp. Asst. U.S. Attys., Sacramento, CA, for I.R.S.

Lawrence J. Loheit, Chapter 13 Trustee, Sacramento, CA.

MEMORANDUM OF DECISION

DAVID E. RUSSELL, Chief Judge.

Chapter 13 Debtors William and Linda Siverling object to a claim made by the Internal Revenue Service (hereinafter the "Service") on grounds that the Service failed to assess Debtors' tax liability within the applicable limitations period. The Service opposes Debtors' objection on the grounds that a timely assessment was made although in violation...

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