OPINION
ERIC G. BRUGGINK, District Judge.
This a suit for refund of federal income tax. Plaintiffs Peter B. McAllister and Jennifer C. McAllister ("the McAllisters" or "plaintiffs") seek a refund of $175,013 for the 2005 tax year resulting from an attempted carryback of a net operating loss ("NOL") from the 2009 tax year. Pending is defendant...
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