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IN RE FROSCH

Bankruptcy No. 98-35948. Adversary No. 99-0240.

261 B.R. 181 (2001)

In re Kevin FROSCH, Debtor. Kevin Frosch, Plaintiff, v. United States of America, City of Philadelphia, Defendants.

United States Bankruptcy Court, W.D. Pennsylvania, Philadelphia Division.

April 10, 2001.

Attorney(s) appearing for the Case

John R. Crayton, Bensalem, PA, counsel for debtor.

Thomas M. Rath, Philadelphia, PA, District counsel for IRS.

MEMORANDUM OPINION1

JUDITH K. FITZGERALD, Chief Judge.

Before the court for resolution following trial, conducted on July 12, 2000, is Debtor's federal income tax liability for years 1989, 1990, 1991, and 1992.2 The IRS contends that the tax liabilities incurred by the Debtor in each of those four years are not dischargeable pursuant to 11 U.S.C. § 523(a)(1)(C). The IRS contends that the

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