Palmer v. United States, Internal Revenue Service (In re Palmer)

ORDER

JOHN L. PETERSON, Chief Judge.

At Butte in said District this 13th day of December, 1996.

In this Chapter 7 bankruptcy, after due notice, hearing was held November 12, 1996, at Billings on Defendant’s Motion for Summary Judgment. Counsel for both parties appeared, and agreed to submit the matter on briefs and exhibits. Both parties have filed briefs and at hearing, each stipulated to the other’s exhibits. The Court, therefore, deems the matter ripe for adjudication.

The matter initially began in April of 1985, when the Internal Revenue Service (IRS) *461issued two Notices of Deficiency; one…