OPINION
WILLIAM H. GINDIN, Bankruptcy Judge.
PROCEDURAL HISTORY
This dispute arises out of a proof of claim filed by the Internal Revenue Service ("IRS") against Roger Pransky for the unpaid portion of an asserted tax liability. Both debtor and the IRS have submitted motions for summary judgment. The issue before this court is whether or not debtor's remittances constitute payments or deposits for purposes of 26 U.S.C. § 6511.
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