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HARRIS v. U.S.

No. 89-3024.

902 F.2d 439 (1990)

J.H. HARRIS, and William J. Martin, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

June 7, 1990.

Attorney(s) appearing for the Case

Warren M. Schultz, Jr., Alexander P. Trostorff, Jones, Walker, Waechter, Poitevent, Carrere & Denegre, New Orleans, La., for plaintiffs-appellants.

Teresa E. McLaughlin, Gary R. Allen, Richard Farber, Chief, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., John P. Volz, U.S. Atty., Eneid Francis, Asst. U.S. Atty., New Orleans, La., Paul M. Predmore, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before JOHNSON, WILLIAMS and GARWOOD, Circuit Judges.

GARWOOD, Circuit Judge:

In this federal income tax refund suit, plaintiffs-appellants, J.H. Harris (Harris) and William J. Martin (Martin), collectively Taxpayers, appeal the district court's summary judgment in favor of defendant-appellee, the United States (Government). We affirm.

Facts and Proceedings Below

In June 1982, Taxpayers contracted with Trans-Lux New Orleans Corporation to purchase for...

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