In Re Black

MEMORANDUM OPINION

FRANK R. MONROE, Bankruptcy Judge.

The Court held a hearing on August 7, 1996, on the Debtors’ Objection to Proof of Claim of the Internal Revenue Service. The Court has considered the arguments of counsel for the parties, the testimony of the witnesses, and post-trial briefs. This Memorandum Opinion is issued as written findings of fact and conclusions of law under Bankruptcy Rules 7052 and 9014.

Findings of Fact

The Debtor, Gary Black, was a commercial airline pilot for Delta Airlines (“Delta”) for 29 years. In 1993, at the age of 57, he voluntarily took early retirement due…