MEMORANDUM OPINION AND DECISION
RICHARD L. SPEER, Bankruptcy Judge.
This cause comes before the Court upon Debtor's Motion for Summary Judgment, Memorandum in Support, and Reply; and Internal Revenue Service's Motion in Opposition, Memorandum in Support, and Notice of Filing. This Court has reviewed the arguments of Counsel, exhibits, as well as the entire record of the case. Based upon that review, and for the following reasons, the Court finds that...
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