MEMORANDUM OPINION
JACK CADDELL, Bankruptcy Judge.
On March 30, 1999, this case came before the Court for trial on the complaint filed by the debtor, Dr. W. David Fretz ("Dr. Fretz"), to determine the dischargeability of his federal income tax liability to the United States, Internal Revenue Service ("IRS"). At the conclusion of the trial, the Court dictated its findings of fact and conclusions of law into the record and determined that judgment was due...
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