Berzon v. United States (In Re Berzon)

MEMORANDUM, OPINION AND ORDER

ROBERT E. GINSBERG, Bankruptcy Judge.

This matter comes before the court on the debtor’s motion for summary judgment with respect to a complaint he filed to determine the dischargeability of certain tax debts the debtor owed the United States. The issue is whether the debtor’s federal income tax liabilities for the years 1981 through 1984 are dischargeable in this Chapter 7 case under 11 U.S.C. § 523 and § 727. The IRS takes the position that the debtor’s tax liability is excepted from a discharge under § 523(a)(1)(C) because debtor failed to file tax returns,…