MEMORANDUM OPINION
JACK CADDELL, Bankruptcy Judge.
On December 8, 1998, this case came before the Court for a trial on the complaint filed by the debtor, Dr. Clyde J. Fontes ("Dr. Fontes"), to determine the dischargeability of his federal income tax liability (Form 1040) to the United States, Internal Revenue Service ("IRS"). At the conclusion of the trial, the Court dictated certain findings of fact and conclusions of law into the record and determined...
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