In re Spenlinhauer

MEMORANDUM

Joan N. Feeney, United States Bankruptcy Judge

I. INTRODUCTION

The matter before the Court is the Motion by Respondent, Robert J. Spenlin-*21hauer (the “Debtor”), for Summary Judgment Relative to Estate Tax Claim of the United States of America. The Debtor’s Motion for Summary Judgment arises in the context of a contested matter initiated by the filing of “Creditor United States of America’s Motion to Determine Tax Liability Pursuant to § 505(a).” Pursuant to that motion, the United States seeks a determi-. nation that the Debtor is personally liable for an estate tax obligation as a…