MEMORANDUM OPINION
THOMAS B. RUSSELL, District Judge.
This matter is before the Court on appeal from the United States Bankruptcy Court for the Western District of Kentucky. Nirmala Noronha appeals the Bankruptcy Court's December 5, 2007 Order (Docket #9). The Appellee, the Internal Revenue Service, filed a Brief in response (Docket #11). Appellant filed a Reply Brief (Docket # 12). The matter is now ripe for adjudication. The Court now
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