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CLARK v. UNITED STATES

Civ. No. 11576.

143 F.Supp. 165 (1956)

Emma J. CLARK et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court S. D. California, Central Division.

March 2, 1956.

Attorney(s) appearing for the Case

Riley & Hall and B. H. Neblett, Los Angeles, Cal., for plaintiffs.

Laughlin E. Waters, U. S. Atty., Edward R. McHale and Eugene Harpole, Asst. U. S. Attys., Los Angeles, Cal., for defendant.

CLARKE, District Judge.

Three basic questions are presented for determination, and are treated under the following headnotes:

Sufficiency of the Claims for Refund.

The plaintiffs contend that the claims for refund filed on the net operating loss carry forward and carry back for the years 1943 and 1944 fully apprised the defendant of the claims for refund on the capital gains issue. The auditing of the returns, conferences and negotiations relating...

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