PORTER v. UNITED STATES

No. 83-5240.

738 F.2d 731 (1984)

Joe Phillip PORTER and Barbara M. Porter, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided June 29, 1984.


Attorney(s) appearing for the Case

Thomas E. Settles, argued, Nashville, Tenn., for plaintiffs-appellants.

Joe Brown, U.S. Atty., Nashville, Tenn., Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Dept. of Justice, Michael L. Paup, Chief, Appellate Section, Kenneth Greene, argued, Washington, D.C., for defendant-appellee.

Before EDWARDS and CONTIE, Circuit Judges, and SPIEGEL, District Judge.


PER CURIAM.

This is a tax refund case to which, as appellants point out, the District Judge gave rather short shrift. Appellants' problem, however, both before the District Judge and this Court, is more the nature of his claim than judicial impatience.

Summary judgment was granted to the defendant Internal Revenue Service on appellants' claim for a tax refund of $4,522, based on a charitable contribution of real property. In 1973, Porter had purchased 6.96...

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