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HARRIS v. UNITED STATES

Civ. A. Nos. 76-674-A, 76-675-A.

431 F.Supp. 1173 (1977)

Robert Lloyd HARRIS and Ellen W. Harris, Plaintiffs, v. UNITED STATES of America, Defendant. Allen C. BYERS and the Estate of Mary M. Byers, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Virginia, Alexandria Division.

May 2, 1977.

Attorney(s) appearing for the Case

Robert D. Grossman, Jr., Springfield, Va., Jon T. Flask, Washington, D. C., for plaintiffs.

S. Martin Teel, Jr., John J. McCarthy, Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION AND JUDGMENT ORDER

CLARKE, District Judge.

I.

Plaintiffs in this action have consolidated for trial by this Court without a jury, their claims for refund of income taxes allegedly assessed against them erroneously. Jurisdiction for the action is based on 28 U.S.C. § 1346(a)(1).

This litigation arises out of a pyramid or "Ponzi" scheme with which this Court has more than passing familiarity. Robert D. Johnson, the...

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