United States v. Williams (In Re Williams)

MEMORANDUM OPINION

SCHLESINGER, District Judge.

Appellant, United States of America, through the Internal Revenue Service (the “Government”) appeals from the Bankruptcy Court’s Findings of Fact, Conclusions of Law and Memorandum Opinion dated January 31, 1994, and from the Final Judgment entered in favor of Debtor/Appellees, James M. Williams, Jr. and Carroll Williams. The Court has jurisdiction pursuant to 28 U.S.C. § 158(a).

In the dispute that gave rise to this appeal, Debtors commenced an adversary proceeding in the Bankruptcy Court in which they sought a determination of the…