MEMORANDUM OF DECISION ON THE MASSACHUSETTS DEPARTMENT OF REVENUE'S MOTIONS FOR SUMMARY JUDGMENT
MELVIN S. HOFFMAN, Bankruptcy Judge.
While the facts in these adversary proceedings are not identical, the fact patterns and legal issues are. It is sensible and efficient, therefore, to issue a single memorandum of decision covering both motions for summary judgment filed by the Massachusetts Department of Revenue ("MDOR") in these matters in which the debtors...
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