United States v. Pastula (In re Pastula)

OPINION

O’MEARA, District Judge.

The United States is appealing the bankruptcy court’s January 7, 1997 decision that the debtors’ 1989-1991 federal income tax liabilities are dischargeable. The United States filed its appellate brief on April 30, 1997. Because debtors Mark and Pamela Pastula are unrepresented on appeal, no brief has been filed on their behalf.1

BACKGROUND

On July 21, 1992, the debtors filed a bankruptcy petition (hereinafter referred to as the “first bankruptcy case”). In that proceeding, the debtors made provision for payment of their 1989-1991 federal tax liabilities. On July…