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UNITED STATES v. WHITE

No. 05-15857.

466 F.3d 1241 (2006)

UNITED STATES OF AMERICA, Plaintiff-Appellant, v. JAMES W. WHITE, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

October 11, 2006.

ANDERSON, Circuit Judge:

The United States appeals the invalidation of its assessment of a tax liability against James White following confirmation of White's Chapter 11 bankruptcy plan. We reverse and direct entry of summary judgment for the Government.

I. BACKGROUND

A. Facts

White was president and sole shareholder of WCC, Inc. On May 3, 1993, White filed a petition for reorganization under Chapter 11 of the Bankruptcy...

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