Abbate v. United States (In Re Abbate)

OPINION

PRO, District Judge.

The debtor, STEVE ABBATE (“Appellant”) appeals the United States Bankruptcy Court’s granting of a summary judgment in favor of the United States with respect to the liabilities set forth on the amended Internal Revenue Service (“IRS”) proof of claim for tax years 1990 through 1993. Finding no merit in the Appellant’s arguments, the Court affirms the decision of the Bankruptcy Court.

I. BACKGROUND

On February 16, 1994, Appellant filed a Chapter 13 bankruptcy petition. On or about May 23, 1994, Appellant filed a pleading entitled “Commencement of Adversary Proceeding…