Callahan v. United States, Internal Revenue Service (In Re Callahan)

CAROL J. KENNER, Bankruptcy Judge.

MEMORANDUM OF DECISION AND ORDER ON MOTIONS OF PLAINTIFF AND DEFENDANT FOR SUMMARY JUDGMENT

By his complaint in this adversary proceeding, the Plaintiff and Debtor, Paul F. Callahan, seeks a determination that income taxes he owes to the United States for tax years 1983 through 1986 are not excepted from discharge by operation of sections 523(a)(1) and 507(a)(7)(A) of the Bankruptcy Code. The adversary proceeding is before the Court now on the parties’ cross-motions for summary judgment.

Both motions focus primarily on whether the tax debt is dischargeable…