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CHRISTOFFERSEN v. UNITED STATES

No. C 82-206.

578 F.Supp. 398 (1984)

Arthur L. CHRISTOFFERSEN and Theresa A. Christoffersen, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Iowa, Cedar Rapids Division.

February 3, 1984.

Attorney(s) appearing for the Case

Thos. M. Collins, Cedar Rapids, Iowa, Arthur S. Rollin, William A. Schmalzl, Thomas Durham, Chicago, Ill., for plaintiffs.

Ludwig H. Adams, Dept. of Justice, Tax Div., Washington, D.C., Evan Hultman, U.S. Atty., Cedar Rapids, Iowa, for defendant.

F. Timothy Hegarty, Jr., Christopher J. Palano, Michael E. Sheehy, Asst. Atty. Gen., Ins. Div., Public Protection Bureau, Boston, Mass., amicus curiae.

ORDER

McMANUS, Chief Judge.

This action for the recovery of federal income taxes paid for the year ending December 31, 1981 was tried to the court on November 21, 1983. All proposed findings of fact and conclusions of law have been received, considered along with the entire record and the court now makes the following:

FINDINGS OF FACT

1. Plaintiffs, husband and wife, are calendar year taxpayers on a cash basis who have resided in Cedar...

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