Chael v. Whyte (In re Whyte)

MEMORANDUM OPINION AND ORDER

KENT LINDQUIST, Chief Judge.

I

Statement of Proceedings and Background

This Adversary Proceeding is before the Court on a Motion filed on October 27, 1992 by the United States of America on behalf of its Agency the Internal Revenue Service (hereinafter: “IRS”) to Alter Judgment or for New Trial (hereinafter: “Motion”). The Motion of the IRS is directed to the Court’s Findings of Fact, Conclusions of Law and Judgment dated October 9,1992, and entered of record on October 14, 1992 (hereinafter: “Judgment”).

The Judgment arose out of an interpleader complaint filed by…