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GOLDBERG v. UNITED STATES

No. 85-5632.

789 F.2d 1341 (1986)

Jerome GOLDBERG and Marjorie Goldberg, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 14, 1986.

Attorney(s) appearing for the Case

Robert C. McDaniel, Burt Barnett, Law Corp., Norwalk, Cal., for plaintiffs-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Mary F. Clark, U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before SCHROEDER and FLETCHER, Circuit Judges, and WILKINS, District Judge.

SCHROEDER, Circuit Judge.

The Goldbergs appeal from the judgment of the district court in favor of the government and disallowing them a refund based upon their claim of a $14,667 interest deduction. The interest was alleged to have been paid on an indebtedness to Anglo Dutch Capital Corporation (Anglo Dutch), now defunct. The district court concluded that neither the "indebtedness" to Anglo Dutch nor the claimed interest payment had any substantial economic purpose...

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