BRUNETTI, Circuit Judge:
James Hatton ("Hatton") failed to file a federal income tax return in 1983, and the Internal Revenue Service ("IRS") instead prepared a substitute return on his behalf. Hatton then entered into an installment agreement with the IRS, agreeing to tender $200 per month in order to fulfill his outstanding tax liabilities. Before Hatton completed all the payments in the installment agreement, he filed a Chapter 7 bankruptcy petition. The IRS filed...
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