MEMORANDUM OPINION AND ORDER
ST. EVE, District Judge.
Appellant United States of America ("Government" or "IRS") appeals the bankruptcy court's denial of its motion for summary judgment and the bankruptcy court's final judgment in which the bankruptcy court concluded that Appellee John Howard Payne's tax liability for the tax year 1986 was properly discharged in bankruptcy. The Court has appellate jurisdiction over this matter pursuant to 28 U.S.C...
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