Rehearing and Rehearing In Banc Denied June 15, 1987.
WILKINSON, Circuit Judge:
Appellants Samuel M. and Betty C. Longiotti claim a refund of federal income taxes based on certain net operating loss carrybacks. The district court granted the government's motion for summary judgment on the ground that the claim was barred by the thirty-nine and a half month statute of limitations set out in section 6511(d)(2)(A) of the Internal Revenue Code. We affirm.
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