MEMORANDUM OPINION
ECONOMUS, District Judge.
This matter is before the Court upon the appeal of Tony Biondic ("Biondic") of a judgment rendered in the United States Bankruptcy Court for the Northern District of Ohio in favor of the United States of America ("Government"). The Bankruptcy Court found that Biondic was collaterally estopped from litigating whether or not his 1980 income tax liability is dischargeable.
For the reasons set forth below...
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