No. 06-15333.

490 F.3d 913 (2007)

In Re: Arthur I. JACOBS, Debtor. United States of America, Plaintiff-Appellee, v. Arthur I. Jacobs, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

June 29, 2007.

Attorney(s) appearing for the Case

Michael G. Tanner, Stuart F. Williams, Tanner Bishop, Jacksonville, FL, for Jacobs.

Bruce R. Ellisen, Ivan C. Dale, U.S. Dept. of Justice, App. Section, Tax Div., Washington, DC, for U.S.

Before PRYOR, KRAVITCH and ALARCÓN, Circuit Judges.

ALARCÓN, Circuit Judge:

Arthur I. Jacobs appeals from the District Court's reversal of an order of the Bankruptcy Court, in which the Bankruptcy Court determined that Mr. Jacobs's federal income tax debt is dischargeable in bankruptcy and that Mr. Jacobs had not willfully attempted to evade or defeat a tax within the meaning of 11 U.S.C. § 523(a)(1)(C). Mr. Jacobs argues that the District Court improperly substituted

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