Rehearing and Rehearing In Banc Denied July 26, 1985.
OPINION OF THE COURT
SLOVITER, Circuit Judge.
I.
FACTS AND PROCEDURAL HISTORY
Plaintiffs Martin Eisenberg and Arthur Nissen were investors in two limited partnerships, Bar Associates (Bar) and Cay Associates (Cay), which were part of a series of limited partnerships designed as tax shelters. Their investment proved worthless and, moreover, the Internal Revenue Service eventually...
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