WEICK, Circuit Judge.
The government appeals in this tax refund case from the grant of summary judgment by the United States District Court for the Western District of Tennessee in favor of the taxpayer-plaintiffs, Charles and Ruth Long, husband and wife. The case concerns the propriety of the government's recapture under the provisions of Section 47(a) of the Internal Revenue Code of 1954 of a $9,867.97 investment tax credit taken by the Longs on their 1972 joint...
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