District Court, N.D. New York April 21, 1993, 92-CV-1563, Bankruptcy No. 90-12465 (Langlois v. United States)

*819

MEMORANDUM DECISION AND ORDER

CHOLAKIS, District Judge.

James Langlois, debtor-appellant, appeals the decision of United States Bankruptcy Judge Justin J. Mahoney granting summary judgment in favor of the Internal Revenue Service (IRS). This Court has jurisdiction over the appeal under 28 U.S.C. § 158(a). Mr. Langlois presents two issues on appeal:

1.