MEMORANDUM OF OPINION ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
JOHN C. AKARD, Bankruptcy Judge.
The Reorganized Trinity Gas Corporation (Reorganized Trinity) filed the captioned adversary proceeding to have the United States of America through its agency, the Internal Revenue Service (IRS), disgorge a $1M payment made in November 1997 for the 1997 estimated joint income tax liability of Sidney W. Sers and his...
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