O'Callaghan v. United States (In Re O'Callaghan)

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND MEMORANDUM OPINION

PAUL M. GLENN, Chief Judge.

THIS CASE came before the Court for a final evidentiary hearing in the above-captioned adversary proceeding.

The Debtor, William O’Callaghan, fíled a petition under chapter 7 of the Bankruptcy Code on September 10, 1999. The United States of America, Internal Revenue Service (IRS) filed a Proof of Claim in the Debtor’s chapter 7 case in the amount of $2,064,558.00 for income tax liabilities for the 1981, 1982, 1983, and 1984 tax years.

The Debtor subsequently commenced this adversary proceeding by filing a…