MEMORANDUM-DECISION, FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER
STEPHEN D. GERLING, Chief Judge.
This matter comes before the Court on a motion by the Internal Revenue Service ("IRS") seeking summary judgment in the adversary proceeding commenced by Robert A. and Elaine K. Chaffee ("Debtors"). Oral argument was heard at a regular motion term of the Court in Syracuse, New York, on March 7, 1995. The parties were afforded an opportunity to file memoranda...
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