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IN RE CAREY

Bankruptcy No. 04-29060-B-7, Adversary No. 04-2548.

326 B.R. 816 (2005)

In re Michael T. CAREY and Leone R. Carey, Debtors. United States of America, Plaintiff, v. Michael T. Carey and Leone R. Carey, Defendants.

United States Bankruptcy Court, E.D. California.

April 25, 2005.

Attorney(s) appearing for the Case

Chaland B. Scrivner, Redding, CA, for Debtors.

MEMORANDUM DECISION

JANE DICKSON MCKEAG, Bankruptcy Judge.

I. INTRODUCTION

The plaintiff United States of America, on behalf of its agency, the Internal Revenue Service (the "IRS"), moves for partial summary judgment on the grounds that findings in prior decisions entered by the United States Tax Court1 (the "Tax Court") should be given issue preclusive effect in this adversary proceeding under the doctrine of...

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