MEMORANDUM OPINION
AFFIRMING THE BANKRUPTCY COURT'S RULING
URBINA, District Judge.
I. INTRODUCTION
This matter comes before the court on an appeal by the Internal Revenue Service ("IRS" or "the appellant") of a ruling by the U.S. Bankruptcy Court for the District of Columbia, granting summary judgment in favor of the District of Columbia against the IRS. The bankruptcy proceeding involved debtor WPG, Inc. ("WPG"), who declared...
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