United States Bankruptcy Court, M.D. Florida March 20, 2003, Bankruptcy Nos. 89-9715-8P1, to 89-9746-8P1, 90-11997-9P1, Adversary No. 91-313 (Hillsborough Holdings Corp. v. United States (In Re Hillsborough Holdings Corp.))

FINDINGS OF FACT, CONCLUSIONS OF LAW AND MEMORANDUM OPINION (ISSUE 35 FOR THE TAX YEARS 1992 THROUGH 1994)

ALEXANDER L. PASKAY, Chief Judge.

These are the confirmed Chapter 11 cases of Hillsborough Holding Corporation and its thirty-two wholly owned subsidiaries (Debtors) and the matter under consideration is a claim set forth in Count VII of the Amended Complaint entitled “Amended Complaint for