MEMORANDUM OPINION
MICHAEL, District Judge.
The government seeks review of a decision and order of the Bankruptcy Court ruling that a debt owed by the Appellees to the IRS, pursuant to 26 U.S.C. § 6672, was discharged upon completion of the Appellees' bankruptcy plan in May, 1993. The court has jurisdiction over this appeal pursuant to 28 U.S.C. § 1334. For the reasons stated
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