BOGGS, Circuit Judge.
The bankrupt plaintiff, Mark Smith, appeals a grant of summary judgment to his major creditor, the United States of America, in an adversary proceeding for a declaration that his debt to the government is dischargeable in bankruptcy. Holding that Smith's debt was not dischargeable, we affirm.
I
Mark Smith filed under Chapter 7 of the Bankruptcy Code on November 23, 1993. At that time, he owed the United States about $140,000...
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