MEMORANDUM OPINION AND ORDER
DAVID H. ADAMS, Bankruptcy Judge.
This matter is before the Court on cross Motions for Summary Judgment filed by the Plaintiff, Red Sea Group, Ltd ("surety") and the Internal Revenue Service, each agreeing that there are no material facts in dispute. The Court has jurisdiction over this proceeding pursuant to 28 U.S.C. § 1334 and 28 U.S.C. § 157(b)(2)(K). This is a core proceeding and the matter is properly postured...
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