OPINION
O'MEARA, District Judge.
The United States is appealing the bankruptcy court's January 7, 1997 decision that the debtors' 1989-1991 federal income tax liabilities are dischargeable. The United States filed its appellate brief on April 30, 1997. Because debtors Mark and Pamela Pastula are unrepresented on appeal, no brief has been filed on their behalf.
BACKGROUND
On July 21, 1992, the...
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