United States v. Payne (In re Payne)

MEMORANDUM OPINION AND ORDER

ST. EVE, District Judge.

Appellant United States of America (“Government” or “IRS”) appeals the bankruptcy court’s denial of its motion for summary judgment and the bankruptcy court’s final judgment in which the bankruptcy court concluded that Appellee John Howard Payne’s tax liability for the tax year 1986 was properly discharged in bankruptcy. The Court has appellate jurisdiction over this matter pursuant to 28 U.S.C. § 158 and Rule 8001 of the Federal Rules of Bankruptcy Procedure. For the following reasons, the Court affirms the bankruptcy court’s decisions.

I.…