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IN RE GRASSGREEN

Nos. 93-0640-3P1, 96-1099-CIV-J-10.

221 B.R. 975 (1998)

In re Richard J. GRASSGREEN, Jr., Debtor. UNITED STATES of America, Appellant, v. Richard J. GRASSGREEN, Jr. and The Enstar Group, Inc., Appellees.

United States District Court, M.D. Florida, Jacksonville Division.

March 25, 1998.

Attorney(s) appearing for the Case

Charles R. Wilson, U.S. Attys. Office, Tampa, FL, Bruce T. Russell, U.S. Dept. of Justice, Tax Division, Washington, DC, for U.S.

J. Marbury Rainer, Michael E. Sumner, Parker, Hudson, Rainer & Dobbs, Atlanta, GA, David Evan Otero, Milam, Otero, Larsen, Dawson, Traylor, P.A., Jacksonville, FL, for Richard J. Grassgreen.

J. Marbury Rainer, Michael E. Sumner, David Evan Otero, Milam, Otero, Larsen, Dawson & Traylor, P.A., Jacksonville, FL, for Enstar Group, Inc.

MEMORANDUM OPINION

HODGES, District Judge.

This case involves an appeal by the Internal Revenue Service (the United States) from an Order and Judgment entered in the United States Bankruptcy Court granting summary judgment in an adversary proceeding pending before that Court. The adversary proceeding was an action brought by the Debtor on his own behalf, and as trustee of the estate, joined by a principal creditor of the estate, seeking a determination...

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