District Court, E.D. Virginia June 23, 2003, CIV.A. 03-30-A (McDow v. Smith)

MEMORANDUM OPINION

ELLIS, District Judge.

In this bankruptcy appeal, the appellee, a debtor with a significant debt to the Internal Revenue Service (“IRS”), seeks to discharge this debt even though, by any fair standard, his annual income is munificent, and he spends much of it on private education for his children and the rental of his large and expensive family home.