ORDER
ROBERT J. McNICHOLS, Senior District Judge.
Currently pending are cross-motions for summary judgment. Perhaps a rarity in refund actions, there are no jurisdictional issues. The motions have been fully briefed and were considered without oral argument on December 9, 1991.
Plaintiffs submitted a Form 1040 together with attachments for calendar year 1983 on or about April 7, 1984. Most lines bore no entry. Every one which did showed a "-0-" except...
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