MEMORANDUM OPINION
ARTHUR B. BRISKMAN, Bankruptcy Judge.
This matter came before the Court on Cross-Summary Judgment Motion by the Internal Revenue Service, on behalf of the United States of America, seeking Partial Summary Judgment and Motion by the Plaintiffs/Debtors, Martin and Susan Collins, for Summary Judgment with respect to the Debtors' Complaint to Determine Dischargeability of Internal Revenue Service Debt pursuant to 11 U.S.C. § 523...
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