JOHN W. PECK, Senior Circuit Judge:
This case is a suit by taxpayer Ruth Gordon to recover payment of a deficiency, plus interest and penalties, which arose as a result of the Internal Revenue Service partially disallowing a refund. This refund had been granted on the basis of joint tax returns by Gordon and her ex-husband and had been credited to a separate tax liability which had been incurred by him. The United States District Court for the Middle District of Florida...
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