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ARDALAN v. UNITED STATES

Civ. A. No. 81-K-1951.

534 F.Supp. 721 (1982)

Shapoor and Harriet ARDALAN, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Colorado.

March 23, 1982.

Attorney(s) appearing for the Case

Marshall I. Whitley, Tax Div., Dept. of Justice, Washington, D. C., for defendant.

George V. Fewson, Dawson L. Joyner, Boulder, Colo., for plaintiffs.

MEMORANDUM OPINION AND ORDER

KANE, District Judge.

This is a tax refund suit against the United States under 28 U.S.C. § 1346(a)(1).1 Plaintiffs allege that throughout 1977 they were citizens and residents of Iran. They further allege that during 1977 neither of them had any income derived from within the United States.2 They also allege that they...

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