ORDER
SILVER, District Judge.
Pending before the Court is an appeal from the bankruptcy court's order denying the Appellant's Motion to Set Aside Order Determining Tax Liability.
Factual Background
On February 16, 1996, Appellee filed for Chapter 7 bankruptcy. On or about August 6, 1996 the Internal Revenue Service ("IRS") filed a proof of claim, listing outstanding tax liability. On November 6, 1996, Appellee filed a Motion for Determination...
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