OPINION
DONALD H. STECKROTH, Bankruptcy Judge.
This matter is before the court upon a motion for summary judgment brought by the United States of America ("United States" or "Plaintiff") in its adversary proceeding against the debtor, Roberto S. Eleazar ("Eleazar" or "debtor"). The United States seeks a determination that the debtor's income tax liabilities are nondischargeable pursuant to 11 U.S.C...
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