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ESTATE OF MANN

No. 82-1593.

731 F.2d 267 (1984)

ESTATE OF Guy L. MANN, Deceased. Suzanne Mann DUVAL, Administratrix, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

May 4, 1984.

Attorney(s) appearing for the Case

Glen L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Sec., Ann Belanger Durney, Robert S. Pomerance, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellant.

Durant, Mankoff, Davis, Wolens & Francis, Charles D. Pulman, Davis, Meadows, Owens, Collier & Zachry, C.M. Meadows, Jr., Dallas, Tex., for plaintiff-appellee.

Before BROWN, WISDOM and JOHNSON, Circuit Judges.

JOHN R. BROWN, Circuit Judge:

Our case today involves loans between a broker and a businessman — two brothers, in two businesses related almost as closely. Because of one bankruptcy, and no bucks, the broker loaned the businessman several million dollars. These loans ultimately were the basis of a bad business debt deduction under I.R.C. § 166, and the resulting tax refund under § 172, filed on behalf of...

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