MEMORANDUM AND ORDER
MacLAUGHLIN, District Judge.
This matter is before the Court on defendant's motion for partial summary judgment. Defendant's motion will be granted.
FACTS
The case before the Court is a refund action brought by plaintiffs Paul and Katherine Villaume to recover income taxes paid by them to the United States for the year 1980. Plaintiffs allege that $17,968 which they received in settlement of a lawsuit is excludable...
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