MEMORANDUM OF DECISION
WILLIAM C. HILLMAN, Bankruptcy Judge.
I. INTRODUCTION
The matters before the Court are the Defendant's, Massachusetts Department of Revenue (the "MDOR"), Motion for Summary Judgment ("MDOR's Motion for Summary Judgment"), the Plaintiff's, Barbara Drake ("Drake"), opposition thereto, Drake's Motion for Summary Judgment ("Drake's Motion for Summary Judgment"), and the MDOR's opposition. Generally, the parties...
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