ORDER GRANTING DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT
GREGORY F. KISHEL, Chief Judge.
This adversary proceeding came on before the Court on November 29, 2000, for hearing on the Defendant's motion for summary judgment. The Defendant ("the United States") appeared by Katja M. Eichinger, Trial Attorney, Tax Division, U.S. Department of Justice. The Plaintiff ("the Debtor") appeared by his attorney, Kenneth E. Keate. Upon the record made for the hearing...
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