MEMORANDUM OPINION AND ORDER
ATLAS, District Judge.
In this appeal from the United States Bankruptcy Court for the Southern District of Texas, Adversary No. 97-4077, Appellant United States of America, Internal Revenue Service ("IRS") contends that the Bankruptcy Court erred in discharging the 1992 tax debt of Appellees Kenneth Warren and Cay Denise Price ("the debtors").
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