MEMORANDUM OPINION
LEE, District Judge.
This is an appeal from an order of the Bankruptcy Court dated November 22, 1999, holding that the imposition of liability by the Internal Revenue Service upon the appellant, Patricia Hornick, in the amount of $87,614.76 as a responsible person pursuant to 26 U.S.C. § 6672(a) is proper and that the liability of the appellant in that regard is excepted from discharge pursuant to 11 U.S.C. § 523(a)(1)(A).
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