MEMORANDUM OPINION
STEPHEN J. COVEY, Bankruptcy Judge.
This matter comes on to be heard upon Debtor's Motion to Disallow Claim of the Internal Revenue Service ("IRS") pursuant to 11 U.S.C. § 502(a). A trial of the matter was held on July 13, and July 28, 1995. At the conclusion of the trial, the Court took the matter under advisement. The parties have submitted post-trial briefs on the issues. After consideration of the evidence presented at the trial...
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