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THOMAS v. U.S.

Civil Action No. 1:96-CV-114-JTC.

967 F.Supp. 505 (1997)

John S. THOMAS, Bobbie J. Thomas, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Georgia, Atlanta Division.

March 18, 1997.

Attorney(s) appearing for the Case

William J. White, William J. White & Associates, Atlanta, GA, for John S. Thomas, Bobbie J. Thomas.

James Randolph Schulz, Office of U.S. Attorney, Northern District of Georgia, Atlanta, GA, Steven M. Webster, U.S. Dept. of Justice, Tax Division, Washington, DC, pro hac vice, for U.S.

ORDER

CAMP, District Judge.

This action is before the Court on Defendant's Motion to Dismiss [# 6-1], or Alternatively, for Summary Judgment [# 6-2].

I. BACKGROUND

Plaintiffs were partners in the White Sands Mall Associates partnership ("White Sands" or the "Partnership") during 1985, 1986, and 1987. White Sands was one of a number of similar partnerships that were audited by the Internal Revenue Service in a group audit project...

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