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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND JANET M. NESSE, Trustee, Appellant vs. * * * * * *

Case No. RWT 03-CV-2223

THE INTERNAL REVENUE SERVICE OF * THE UNITED STATES OF AMERICA, * * Appellee * ORDER Having considered the briefs filed by the parties, the record on appeal, the arguments presented by counsel at a hearing held on February 10, 2004, and for the reasons stated in the Memorandum Opinion filed in conjunction with this Order, it is this 19th day of February, 2004, by the United States District Court for the District of Maryland, ORDERED that the decision of the Bankruptcy Court is, and shall be, AFFIRMED .

/s/ ROGER W. TITUS UNITED STATES DISTRICT JUDGE



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