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ARONSOHN v. C.I.R.

No. 92-7444.

988 F.2d 454 (1993)

Jeff D. ARONSOHN; Evelyn J. Aronsohn, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE; United States of America.

United States Court of Appeals, Third Circuit.

Decided March 17, 1993.

Attorney(s) appearing for the Case

Patrick M. Connolly, Scranton, PA, for appellants.

James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Jonathan S. Cohen, Billie L. Crowe, David A. Shuster, Tax Div., Dept. of Justice, Washington, DC (James J. West, U.S. Atty., of counsel), for appellee.

Before: MANSMANN, SCIRICA and FEINBERG, Circuit Judges.

Submitted Under Third Circuit Rule 12(6) February 25, 1993.

OPINION OF THE COURT

MANSMANN, Circuit Judge.

We are asked to interpret Internal Revenue Code waiver Form 870-AD on appeal from the district court's final order of June 17, 1992, granting summary judgment in favor of the United States of America. The Aronsohns contend that the language of Form 870-AD plainly indicates that an agent may bindingly execute the agreement represented in that...

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