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SUFFNESS v. U.S.

Civ. A. No. CA3-90-1154-P.

788 F.Supp. 304 (1992)

Michael B. SUFFNESS and Dorit R. Suffness, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Texas, Dallas Division.

January 10, 1992.

Attorney(s) appearing for the Case

Michael B. Suffness and Dorit R. Suffness, pro se.

Jon E. Fisher, Trial Atty., Tax Div., Dept. of Justice, Dallas, Tex., for U.S.

MEMORANDUM OPINION AND ORDER

SOLIS, District Judge.

Now before the Court is Defendant's Motion for Judgment on the Pleadings or for Summary Judgment, filed November 15, 1991, and Plaintiffs' Motion for Judgment on the Pleadings or for Summary Judgment, filed November 26, 1991.

FACTS

On May 28, 1987, Plaintiffs Michael B. Suffness and Dorit R. Suffness ("Plaintiffs") filed their 1986 joint income tax return with an election under 26 U.S...

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