MEMORANDUM OF DECISION AND ORDER
SPATT, District Judge:
This is an appeal from two decisions of United States Bankruptcy Judge Dorothy Eisenberg dated October 28, 1994 and May 19, 1995. These appeals arise out of a tax assessment by the New York State Department of Taxation and Finance ("Department of Taxation" or the "State") on the sales of cooperative units by the Debtor-Appellant, E. Thomas Williams, Jr. ("Williams"). According to the Department of Taxation...
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