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CONWAY v. U.S.

Civ. A. No. MJG-93-1707.

908 F.Supp. 292 (1995)

Patrick J. CONWAY, et ux., Plaintiffs and Counterclaim Defendants, v. UNITED STATES of America, Defendant.

United States District Court, D. Maryland.

August 10, 1995.

Attorney(s) appearing for the Case

Edward L. Blanton, Jr., Baltimore, MD, for plaintiffs.

Michael J. Salem, Trial Attorney, Tax Div., U.S. Dept. of Justice, Washington, DC, Edward J. Snyder, Chief, Civil Trial Section — Eastern Region, U.S. Department of Justice, Washington, DC, for defendant.

MEMORANDUM AND ORDER

GARBIS, District Judge.

The Court has before it the United States' Motion for Summary Judgment, United States' [Second] Motion for Summary Judgment, Plaintiffs' Motion for Summary Judgment and the materials submitted by the parties relating thereto. The Court has held a hearing and had the benefit of the arguments of counsel.

The Court recognizes that Mr. and Mrs. Conway ("the Taxpayers") acted in good faith and without...

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