MEMORANDUM OF OPINION
DAVID F. SNOW, Bankruptcy Judge.
The Debtor, Edward J. Sullivan, Jr., seeks a declaration that more than four million dollars in taxes, penalties, and interest are dischargeable under section 523(a)(1)(B)(ii) of the Bankruptcy Code. Both the Debtor and the Internal Revenue Service (the "IRS") filed cross-motions for summary judgment and have stipulated the facts required for the Court's decision. This is a core proceeding under 28 U...
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