VANCE, Circuit Judge:
This is an appeal by taxpayers from a summary judgment for the government for a federal income tax refund suit. We reverse.
The precise question before the court appears simple: Is there a genuine issue of material fact as to what taxpayer Barbara I. Shook settled in exchange for a $200,000 convertible note that she received? The details, however, are much more complicated.
A logical starting point is April 15, 1943 when each...
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