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ROBINSON v. U.S.

No. Civ. 98-1456-RE.

84 F.Supp.2d 1124 (1999)

Gerald S. and Sheryl ROBINSON, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Oregon.

November 8, 1999.

Attorney(s) appearing for the Case

Thomas H. Tongue, Robert K. Winger, Dunn, Carney, Allen, Higgins & Tongue, Portland, OR, for Plaintiff.

Kristine Olson, United States Attorney, District of Oregon, Portland, OR, Michael J. Desmond, Jennifer Whang, United States Department of Justice, Tax Division, Washington, DC, for defendant.

OPINION AND ORDER

REDDEN, District Judge.

This is an action for tax refunds totaling approximately $248,000. Of the total, plaintiffs claim a refund of $100,102.50 in taxes, interest and penalties for the 1991 tax year, and $147,842.00 in taxes, interest and penalties for the 1988 tax year.

The matter before the court is the United States' motion for partial summary judgment. The United States seeks a determination from the court that:

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