MEMORANDUM OF DECISION ON MOTION FOR SUMMARY JUDGMENT
H.F. WHITE, Bankruptcy Judge.
This matter is before the court on the motion for summary judgment filed by the defendant, the United States of America ("USA" or "Government"), related briefs and stipulations of fact filed by the parties. The parties agreed to submit all papers necessary for the court to make the decision on the complaint. The issue in the complaint is whether the debtors' income taxes...
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