Nilsen v. Massachusetts Department of Revenue (In re Nilsen)

MEMORANDUM

Joan N. Feeney, United States Bankruptcy Judge

I. INTRODUCTION

The matters before the Court are the Motion of the Massachusetts Department of Revenue for Judgment on the Pleadings and the Motion of the United States of America1 for Judgment on the *642Pleadings and, in the Alternative, Summary Judgment (together, the “Motions”) with respect to the three count Complaint, captioned “Complaint to Determine Dis-chargeability of Debts,” filed by the Debt- or, Johan K. Nilsen (the “Debtor”). Through his Complaint, the Debtor seeks a determination that taxes, penalties and interest owed by him…