OPINION
A. POPE GORDON, Bankruptcy Judge.
The debtor filed a complaint under 11 U.S.C. § 505 to determine the debtor's 1991 income tax liability to the Internal Revenue Service.
The government filed a motion for summary judgment which the parties submitted to the court on briefs of counsel.
The undisputed facts are as follows.
The debtor recovered a $1,016,765.82 judgment...
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