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HEALY v. U.S.

Civ. No. 92-4008.

843 F.Supp. 562 (1994)

Patrick HEALY and Carolyn Healy, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. South Dakota, S.D.

February 3, 1994.

Attorney(s) appearing for the Case

John E. Burke, Sioux Falls, SD, for plaintiffs.

Charles P. Hurley, Trial Atty., Washington, DC, for defendant.

MEMORANDUM OPINION and ORDER

JOHN B. JONES, Chief Judge.

Patrick and Carolyn Healy seek a refund of federal income taxes for the years 1985 through 1988, in the amount of $20,012.70, plus interest. The Healys contend that the rate they used for valuing the benefit they received as income for federal tax purposes as a result of life insurance benefits paid by Patrick's employer meets the requirements of Internal Revenue Service revenue rulings.

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