ORDER
WILLIAM S. SHULMAN, Chief Judge.
This matter is before the Court on the motion for summary judgment filed by the United States (sometimes hereinafter referred to as "IRS"). The Court has jurisdiction to hear this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Order of Reference of the District Court. This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). After consideration of the pleadings, evidence, briefs...
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