THORNBERRY, Circuit Judge:
The United States appeals the district court's judgment in favor of taxpayer Hans Rasmussen on Rasmussen's claim for refund of overpaid federal income tax. We agree with the United States that Rasmussen did not satisfy the mitigation provisions of the Internal Revenue Code, and the statute of limitations therefore bars his claim.
On October 23, 1984, Hans Rasmussen, as sole shareholder and liquidator of Canal Marine Repairs, Inc...
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