MEMORANDUM OPINION AND ORDER
STEVENS, District Judge.
This is a taxpayer's refund suit under 28 U.S.C. § 1346(a)(1). The taxpayer, Thomas Stilwell, requested a refund of $29,426.77 together with interest. On March 29, 1982, after an audit determination, the Internal Revenue Services issued statutory notification of disallowance.
In 1973 the taxpayer had acquired 59.6 shares of Ketcham Oldsmobile, Inc. capital stock with a cost or basis of $60...
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