Ragone v. Internal Revenue Service (In re Ragone)

MEMORANDUM OPINION

DOWD, District Judge.

This is an appeal from the July 19, 1994 decision and judgment entry of Judge Harold White of the Bankruptcy Court granting the motion of the United States of America for summary judgment on the application of Frank A. Ragone for a discharge from the debt presented by the Internal Revenue Service by way of a proof of claim totalling $334,926.56. The proof of claim asserted that the debtor owed certain sums of money for federal income taxes, interest, and penalties for the years 1973, 1974 and 1975 and for trust fund taxes, as well as interest and…