OPINION AND ORDER
DONALD E. CORDOVA, Bankruptcy Judge.
THIS MATTER came on for trial on June 10, 1996, on the Plaintiff, United States of America's ("IRS") Complaint to Determine Dischargeability of defendant's 1978 and 1981 federal income tax deficiencies pursuant to 11 U.S.C. § 523(a)(1)(C). Based upon the evidence presented at trial, the Court makes the following findings of fact and conclusions of law.
FACTUAL FINDINGS
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