FAIRCHILD, Circuit Judge.
Appellant taxpayer Leroy Doyle appeals from the district court's order granting summary judgment in favor of the Internal Revenue Service on Mr. Doyle's counterclaim and granting partial summary judgment in favor of the Service on its main claim.
On July 18, 1978, Doyle was arrested at his residence in Milwaukee for possession of controlled substances including cocaine, heroin, marijuana and barbiturates. In searching his residence...
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