MEMORANDUM DECISION REGARDING MOTION FOR SUMMARY JUDGMENT
W. RICHARD LEE, Bankruptcy Judge.
Before the court is a motion for summary judgment (the "Motion") brought by the defendant in this adversary proceeding, the Internal Revenue Service (the "IRS"). This Motion is opposed by the debtors and plaintiffs, Kevin and Susan Martin (the "Martins"), who have asked the court to rule in their favor based on the same set of undisputed facts. The Martins seek a...
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