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IN RE STEINKRAUSS

Bankruptcy No. 97-19549-WCH. Adversary No. 98-2210.

313 B.R. 87 (2004)

In re Joseph C. STEINKRAUSS and Donna E. Steinkrauss, Debtors. Joseph C. Steinkrauss and Donna E. Steinkrauss, Plaintiffs, v. United States of America, Defendant.

United States Bankruptcy Court, D. Massachusetts, Eastern Division.

July 8, 2004.

Attorney(s) appearing for the Case

Jeffrey J. Cymrot, Sassoon and Cymrot, Boston, MA, for Debtors and Plaintiffs.

Timothy M. Mauser, Mauser & Mauser, Boston, MA, for Debtors.

Harold B. Murphy, Hanify & King, P.C., Boston, MA, for trustee.

Edward DeFranceschi, Boston, MA, for Plaintiffs.

Alejandro L. Bertoldo, Carina J. Campobasso, Trial Attorney, Tax Division, US Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OF DECISION

WILLIAM C. HILLMAN, Bankruptcy Judge.

I. Introduction

Joseph C. Steinkrauss and Donna E. Steinkrauss ("Joseph", "Donna", and collectively the "Debtors") brought this adversary proceeding against the United States of America ("United States") to determine the amount and dischargeability of their federal income taxes for the years 1986 through 1993 inclusive. The IRS countered that the Debtors willfully attempted...

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