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SNELL v. UNITED STATES

No. 81-2025.

680 F.2d 545 (1982)

Robert M. SNELL and Rosalie J. Snell, husband and wife, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 18, 1982.

Attorney(s) appearing for the Case

John P. Raynor, Omaha, Neb., for appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Jonathan S. Cohen, Stephen Gray, Attys., Tax Division, Dept. of Justice, Washington, D. C., for appellee.

Before BRIGHT and McMILLIAN, Circuit Judges, and HARRIS, Senior District Judge.

McMILLIAN, Circuit Judge.

Robert M. Snell and Rosalie J. Snell, husband and wife, appeal an order entered in the District Court1 for the District of Nebraska granting the government's motion for summary judgment in the Snells' tax refund suit based on the district court's finding that a taxpayer is not entitled to, as a deduction, partnership losses which had accrued prior to the taxpayer's entry into the partnership. For reversal the...

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