MEMORANDUM OPINION AND ORDER
ZATKOFF, District Judge.
This matter is before the Court on defendant's Fed.R.Civ.P. 56(b) motion for summary judgment. For the reasons stated below, defendant's motion is granted.
I. BACKGROUND
Plaintiff Joseph Abadi claimed a business loss deduction of $200,460.00 on his 1978 individual federal income tax return. The deduction arose from his investment of $52,000.00 in November of 1978 in a tax shelter named...
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