MEMORANDUM AND ORDER
SEYBERT, District Judge.
Plaintiffs Joseph and Tita Monti filed the instant action on January 30, 1996 against the United States claiming a refund of certain partnership taxes they paid in 1982, 1983, 1984 and 1985. Specifically, plaintiffs claim that they were essentially "overcharged" for taxes derived from their investment in Syn-Fuel Associates, 1982 ("Syn-Fuel"), of which they...
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