MEMORANDUM OPINION AND ORDER
FOLSOM, District Judge.
This matter comes before the Court on appeal from the United States Bankruptcy Court, filed September 22, 1995. The United States of America through the Internal Revenue Service, (hereinafter "the IRS"), appeals two separate orders entered by the bankruptcy court. One Order granted Dudley Davis Taylor's (hereinafter "Debtor") motion for summary judgment. The other denied the IRS' cross-motion for...
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