OPINION
SUSAN H. BLACK, District Judge.
This is a claim for tax refund by the individual limited partners of Financial Dynamics, Ltd., a Florida limited partnership. The United States has counterclaimed for excess taxes due. There is no dispute that the partnership is liable for the taxes; the only question is whether the individual partners are personally liable.
On September 2, 1971, Financial Dynamics, Ltd. was formed as a limited partnership...
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