LONGIOTTI v. UNITED STATES

No. C-85-120-D.

635 F.Supp. 840 (1986)

Samuel M. LONGIOTTI and Betty C. Longiotti, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, M.D. North Carolina, Durham Division.

June 5, 1986.


Attorney(s) appearing for the Case

H. Bryant Ives, III and Sally Nan Barber, Charlotte, N.C., for plaintiffs.

Richard F. Mitchell, Tax Div., Dept. of Justice, Washington, D.C., for defendant.


MEMORANDUM OPINION

ERWIN, District Judge.

This matter is before the court on cross motions by the parties for summary judgment, pursuant to Rule 56 of the Federal Rules of Civil Procedure. Both parties have fully briefed the issues before the court, and argument was heard on May 22, 1986 in Greensboro. The case is now ready for a ruling.

Facts

This is an income tax case concerning plaintiffs...

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