BRIMMER, District Judge, sitting by designation.
Background
Appellee Harry Litwin initially brought suit to recover income taxes and interest he allegedly overpaid for tax years 1983 and 1984. The district court held that Litwin was not liable for certain tax assessments and ordered appellant, the United States, to refund Litwin's overpayment. The issue before this Court is whether, under the "clearly erroneous" standard of review, the evidence supports...
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