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IN RE SIMONE

Bankruptcy No. 97-13645SR. Adversary No. 97-0984.

252 B.R. 302 (2000)

In re Robert F. SIMONE, Debtor. Robert F. Simone, Plaintiff, v. United States of America, Internal Revenue Service, Defendant.

United States Bankruptcy Court, E.D. Pennsylvania.

April 20, 2000.

Attorney(s) appearing for the Case

Steven B. Mirow, Philadelphia, PA, for Robert F. Simone.

Mitchell W. Miller, Philadelphia, PA, trustee.

MEMORANDUM OPINION

JOSEPH L. COSETTI, Bankruptcy Judge.

The matter before the court is the Motion for Summary Judgment filed by Defendant United States of America, Internal Revenue Service seeking a determination that the tax liability owed by Debtor/Plaintiff Robert F. Simone is nondischargeable. For the reasons expressed below, the motion for summary judgment shall be granted in part and denied in part.

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