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IN RE ABERL

No. 95-3017.

78 F.3d 241 (1996)

In re George E. ABERL; Lois J. Aberl, Debtors. UNITED STATES of America, Appellant, v. George E. ABERL; Lois J. Aberl, Appellees.

United States Court of Appeals, Sixth Circuit.

Decided March 7, 1996.

Attorney(s) appearing for the Case

Charles S. Owen (argued and briefed), Gatto, Bennett & Owen, Southfield, MI, for petitioner.

David J. Kline, Brenda E. Ellison (argued and briefed), U.S. Dept. of Justice, Immigration Litigation, Civ. Div., Washington, DC, Edmund A. Sargus, Jr., U.S. Atty., Columbus, OH, for respondent.

Before: MERRITT, Chief Judge; CONTIE and BOGGS, Circuit Judges.

CONTIE, Circuit Judge.

The bankruptcy court discharged the federal income tax liabilities of George and Lois Aberl for the 1981 and 1983 tax years. The district court affirmed the bankruptcy court. For the following reasons, we affirm.

I.

On May 23, 1990, the Internal Revenue Service ("IRS") mailed George and Lois Aberl ("Aberls" or "the Debtors") a notice of deficiency for the 1981 and 1983 tax years. On August 21, 1990, the Aberls submitted an...

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