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HARRIS v. UNITED STATES

No. 84-8424.

768 F.2d 1240 (1985)

Ralph D. HARRIS and Joan F. Harris, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

August 14, 1985.

Attorney(s) appearing for the Case

Michael L. Paup, Chief, Appellate Section, Glenn L. Archer, Jr., Asst. Atty. Gen., David English Carmack, Washington, D.C., for defendant-appellant.

David J. Kiyonaga, Jacksonville, Fla., Darrell F. Brown, Little Rock, Ark., for plaintiffs-appellees.

Dwight A. McKabney, Miami, Fla., Allan I. Mendelsohn, Marvin L. Szymkowicz, Washington, D.C., for amicus curiae Wm. & Vivian De La Mater, et al.

Before KRAVITCH and CLARK, Circuit Judges, and WRIGHT, Senior Circuit Judge.

EUGENE A. WRIGHT, Circuit Judge:

During 1979, Ralph and Joan Harris resided in the territory within the Republic of Panama that formerly constituted the Canal Zone. They worked for and received a salary from the Panama Canal Commission (PCC). They filed a joint federal income tax return and paid taxes allegedly due. In 1980, the Harrises filed a refund claim for excess taxes of $6,647 paid in 1979. The claim constituted...

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