In re Kardash

MEMORANDUM OPINION AND ORDER GRANTING DEBTOR’S MOTION FOR SUMMARY JUDGMENT AND SUSTAINING DEBTOR’S OBJECTION TO CLAIM

K. Rodney May, United States Bankruptcy Judge

The parties have filed competing motions for summary judgment on the Debt- or’s objection to the proof of claim filed by the United States of America on behalf of the Internal Revenue Service (the “United States”).1 The United States asserts that the Debtor’s liability from a Tax Court judgment, for his having received about $4.3 million of fraudulent transfers from the corporate taxpayer, is equivalent to a “tax” and, therefore, the…