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IN RE MACAGNONE

No. 8:00-CV-563-T-24B.

253 B.R. 99 (2000)

In re Frank P. MACAGNONE and Santina Macagnone, Debtors. United States of America, Appellant, v. Frank P. Macagnone and Santina Macagnone, Appellees.

United States District Court, M.D. Florida, Tampa Division.

June 13, 2000.

Attorney(s) appearing for the Case

Philip Doyle, U.S. Dept. of Justice, Tax Division, Washington, DC, for Appellants.

Nicholas B. Bangos, Adorno & Zeder, P.A., Miami, FL, for appellees.

ORDER

BUCKLEW, District Judge.

This cause comes before the Court on the United States of America's appeal from the United States Bankruptcy Court's Order on Remand entered January 27, 2000. (B.C. Dkt. 79). Briefs have been filed by both parties, and appellant has also filed a Reply Brief. (B.C. Dkt. 5,6 & 7).

I. Background

In 1982, appellee Frank P. Macagnone ("Macagnone") formed American Management and Development...

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