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SMELLEY v. U.S.

No. 92-7036.

3 F.3d 389 (1993)

Lawrence D. SMELLEY; June Morrison Smelley, Plaintiffs-Appellants, v. UNITED STATES of America (Internal Revenue Service), Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

September 30, 1993.

Attorney(s) appearing for the Case

Lindsey M. Davis, Florence, AL, for plaintiffs-appellants.

Jack W. Selden, George C. Batcheler, Birmingham, AL, Gary Allen, Edward T. Perelmuter, Michael L. Paup, U.S. Dept. of Justice, Tax Div., Ann B. Durney, Jonathan A. Wasserman, U.S. Dept. of Justice, Washington, DC, for defendant-appellee.

Before TJOFLAT, Chief Judge, EDMONDSON, and CARNES, Circuit Judges.

PER CURIAM:

The judgment of the district court is affirmed for the reasons stated in the district court's memorandum opinion which is published at 806 F.Supp. 932 (N.D.Ala.1992).

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