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BJERKE v. U.S.

Civ. No. A3-86-26.

677 F.Supp. 633 (1987)

Leon A. BJERKE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. North Dakota, Southeastern Division.

September 25, 1987.

Attorney(s) appearing for the Case

R.E.T. Smith, Wahpeton, N.D., for plaintiff.

Mark G. Fraase, Trial Atty., Tax Div. U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION AND ORDER

JOHN B. JONES, District Judge, Sitting by Designation.

Plaintiff Leon A. Bjerke brings this action against the United States to recover taxes. The parties have submitted this action on stipulated facts, and the stipulated facts are so found.

This action presents a single issue: Is the plaintiff, as a limited partner, "at risk" under 26 U.S.C. section 465(b)(2) for the amount of the limited partnership's debts that he...

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