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FARMAR v. UNITED STATES

Nos. 15-80T, 16-80T.

689 F.2d 1017 (1982)

Philip D. FARMAR and Marian J. Farmar, and A. A. and Mary S. Sugg v. The UNITED STATES.

United States Court of Claims.

Certiorari Granted January 10, 1983.

Attorney(s) appearing for the Case

William M. Linden, Houston, Tex., for plaintiffs. James A. Carter, attorney of record. Marvin K. Collie and Vinson & Elkins, Houston, Tex., of counsel.

Maxine C. Champion, Washington, D. C., with whom was Asst. Atty. Gen., John F. Murray, Washington, D. C., for defendant. Theodore D. Peyser, Jr., and Donald H. Olson, Washington, D. C., of counsel.

Before COWEN, Senior Judge, DAVIS and NICHOLS, Judges.

Certiorari Granted January 10, 1983. See 103 S.Ct. 722.

ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND PLAINTIFFS' CROSS-MOTION FOR SUMMARY JUDGMENT

DAVIS, Judge.

Plaintiffs, Philip D. and Marion J. Farmar, and A. A. and Mary S. Sugg, bring these consolidated refund suits to recover deficiencies assessed by the Internal Revenue Service (IRS or Service) for the taxable year 1976. Farmar and Sugg are owners of a mineral estate in lands located in Texas...

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