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COPLIN v. UNITED STATES

Appeal Nos. 85-504 to 85-507.

761 F.2d 688 (1985)

Paul H. and Patricia COPLIN, Appellees, v. The UNITED STATES, Appellant. Robert E. O'CONNOR, et ux., Gladys E. O'Connor, Appellees, v. The UNITED STATES, Appellant. Jon D. COFFIN, Appellee, v. The UNITED STATES, Appellant. Jack R. and Maria R. MATTOX, Appellees, v. The UNITED STATES, Appellant.

United States Court of Appeals, Federal Circuit.

May 10, 1985.

Attorney(s) appearing for the Case

Michael Paup, Tax Div., Dept. of Justice, Washington, D.C., argued for appellant. With him on brief were Glenn L. Archer, Jr., Asst. Atty. Gen. and David English Carmack, Washington, D.C.

Andrew Barnard, Barnard, P.A., Miami, Fla., argued for appellees Paul H. and Patricia Coplin. With him on the brief were George S. Barnard and Beverly Barnard Parker, Miami, Fla.

David J. Kiyonaga and Michael C. Pierce, Balboa, Republic of Panama, of counsel.

Allan I. Mendelsohn, Ward & Mendelsohn, Washington, D.C., argued for appellees Robert E. O'Connor, et ux. and Gladys E. O'Connor. With him on the brief was Marvin L. Szymkowicz, Washington, D.C.

Dwight A. McKabney, APO, Miami, Fla., of counsel.

John C. Morrison, Kiefer & Morrison, Washington, D.C., was on brief for appellees, Jack R. and Maria R. Mattox.

Elisabeth A. Walker and Darrell F. Brown, Darrell F. Brown and Associates, P.A., Little Rock, Ark., were on brief, for appellee Jon D. Coffin.

Before RICH, BALDWIN, SMITH, NIES and BISSELL, Circuit Judges.

BISSELL, Circuit Judge.

The government appeals from a decision of the United States Claims Court holding that United States citizens employed by the Panama Canal Commission are exempt from United States income tax. We reverse.

BACKGROUND

These appeals were consolidated by order of this court dated October 22, 1984, and involve suits for the refund of federal income taxes. Paul Coplin, Robert O'Connor, Jon Coffin, and Jack Mattox are United States...

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