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IN RE JONES

BAP No. ID-96-1741-ROV, Bankruptcy No. 95-01380, Adv. No.95-6140.

208 B.R. 935 (1997)

In re Dale D. JONES and Leah B. Jones, Debtors. Dale D. JONES and Leah B. Jones, Appellants, v. UNITED STATES of America, Internal Revenue Service, Appellee.

United States Bankruptcy Appellate Panel of the Ninth Circuit.

Decided April 30, 1997.

Attorney(s) appearing for the Case

Brent T. Robinson, Ling, Nielsen & Robinson, Rupert, for Debtors.

Richard R. Ward, Trial Attorney, Tax Division, U.S. Department of Justice, Washington, DC, for U.S.

Before: RUSSELL, OLLASON, and VOLINN, Bankruptcy Judges.

OPINION

RUSSELL, Bankruptcy Judge:

Dale and Leah Jones appeal the summary judgment granted by the bankruptcy court confirming their tax liability in the amount of $411,318.98. We VACATE and REMAND for trial consistent with this opinion.

I. FACTS

The plaintiffs/debtors Dale and Leah Jones ("debtors") appeal the summary judgment motion granted by the United States Bankruptcy Court for the...

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