No. 82-8738.

727 F.2d 1043 (1984)

UNITED STATES of America, Plaintiff-Appellee, v. D.N. STAFFORD and Flora C. Stafford, Defendants-Appellants.

United States Court of Appeals, Eleventh Circuit.

March 19, 1984.

Attorney(s) appearing for the Case

William B.B. Smith, Atlanta, Ga., for defendants-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Michael L. Paup, Chief, Appellate Section, Stanley S. Shaw, Jr., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before ANDERSON and CLARK, Circuit Judges, and DUMBAULD, District Judge.


Taxpayers DeNean and Flora Stafford appeal the district court's summary judgment in favor of the government on their refund action for allegedly overpaid taxes. The refund action involves the Staffords' 1969 tax return, in which they did not account for their receipt of a limited partnership interest valued at $100,000. The taxpayers argue that the partnership share qualified for nonrecognition treatment under I.R.C. §...

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