MEMORANDUM
ROBERT J. WOODSIDE, Bankruptcy Judge.
Procedural and Factual History
Before me is the Defendant's Motion to Dismiss the Debtors' Complaint which seeks a declaration that their federal income tax liabilities for tax years 1988 through 1996 are dischargeable and that the Defendant must release a lien which it holds against Debtor Jan C. Polston. The stipulated facts are as follows.
The Debtors did not file tax returns...
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