R & L Refunds, Inc. v. United States (In Re R & L Refunds, Inc.)

MEMORANDUM OPINION

J. WENDELL ROBERTS, Bankruptcy Judge.

This Adversary Proceeding is before the Court on the parties’ cross-motions for Summary Judgment pursuant to Fed.R.Civ. Pro. 56 and Fed.R.Bankr.Pro. 7056. Briefs in support of the parties’ respective positions have been filed and reviewed. For the reasons set forth below, we overrule the Plaintiff’s Motion for Summary Judgment and sustain the Defendant’s Motion for Summary Judgment.

The material facts which give rise to this action are as follows. R & L Refunds, Inc. (“Plaintiff”) is in the business of loaning money to individuals by…