MEMORANDUM OPINION AND ORDER
STEVEN A. FELSENTHAL, Bankruptcy Judge.
Dale L. McCullough, the Chapter 7 trustee of the bankruptcy estate of Billy G. Armstrong, the debtor, brought this action pursuant to 11 U.S.C. § 505 to recover $126,240.00, which is the agreed amount of the overpayment of taxes for the 1984 tax year. The United States filed a motion to dismiss or, in the alternative, for summary judgment. McCullough filed his own motion for...
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