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IN RE CALLERY

No. 97-48586.

274 B.R. 51 (2002)

In re Brian J. CALLERY.

United States Bankruptcy Court, D. Massachusetts.

March 1, 2002.

Attorney(s) appearing for the Case

Richard A. Savrann, Gargill Sassoon & Randolph, Boston, MA, for Brian J. Callery.

Jeffrey S. Ogilvie, Boston, MA, for Massachusetts Dep. of Rev.

Stephen J. Turanchik, Civil Trial Section, Northern Region, U.S. Dep. of Justice, Washington, DC, for Internal Revenue Service.

FINDINGS OF FACT AND RULINGS OF LAW

JOEL B. ROSENTHAL, Bankruptcy Judge.

Before the Court for determination are Objections to Proofs of Claim filed by Brian J. Callery (the "Debtor") relative to income taxes claimed as owed to the United States Internal Revenue Service ("IRS") and the Massachusetts Department of Revenue ("MDOR").

I. FINDINGS OF FACT

Between 1994 and 1996, the Debtor was involved in the so-called "diversion...

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