MEMORANDUM OPINION
DWIGHT H. WILLIAMS, Jr., Bankruptcy Judge.
In this adversary proceeding, Daryl Zain Perry ("Perry") seeks a determination that any amounts owed to the Internal Revenue Service ("IRS") for tax years 1997, 1999, 2001, and 2003 are dischargeable.
On June 6, 2012, Perry filed a motion for judgment on the pleadings. Following a hearing on Perry's motion, which the IRS opposed, the court converted Perry's motion to one seeking summary...
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