MEMORANDUM OPINION
HARPER, District Judge.
Plaintiffs in the above two cases (and plaintiff, Dan Neidballa, in Cause No. 86-1587C(2), previously dismissed), brought an action against the defendant seeking a refund of Federal taxes paid, an abatement of the remaining taxes assessed against them, and attorneys' fees.
The United States counterclaimed for the balance of the assessments against plaintiffs, and brought an action against Cynthia Kretmar...
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