OPINION ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
WILLIAM R. GREENDYKE, Bankruptcy Judge.
On April 3, 1995 Debtors, John and Helga Miller, filed the instant adversary proceeding seeking a determination that their 1986 and 1989 income taxes are not entitled to priority status, and consequently, are dischargeable pursuant to 11 U.S.C. § 507(a)(8) and § 523(a)(1). Subsequently, on July 12, 1995 Defendant, Internal Revenue Service, filed a motion...
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