MEMORANDUM OPINION
JOHN H. SQUIRES, Bankruptcy Judge.
This matter comes before the Court on the motion of the United States of America Internal Revenue Service (the "IRS") to partially dismiss the motion of Martha L. Schmidt, Mary Ann Scharifi, Arthur D. Welton, Richard Welton, Harold Welton, William Welton, Sara Hancock, and Nancy Hayner (collectively the "Debtors") pursuant to 11 U.S.C. § 505(a) to determine tax liability. For the reasons set...
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