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KOSS v. U.S.

No. 95-1154.

69 F.3d 705 (1995)

David A. KOSS; Freya B. Koss, Appellants v. UNITED STATES of America.

United States Court of Appeals, Third Circuit.

Decided November 7, 1995.

Attorney(s) appearing for the Case

David A. Koss (argued), Wynnewood, PA, for Appellants.

Loretta C. Argett, Assistant Attorney General, Gary R. Allen, Kenneth L. Greene, Sara Ann Ketchum (argued), Attorneys Tax Division, Department of Justice, Washington, D.C., and Michael R. Stiles, United States Attorney, Philadelphia, PA, for Appellee.

Before: GREENBERG, LEWIS and ROSENN, Circuit Judges.

OPINION OF THE COURT

GREENBERG, Circuit Judge.

I. FACTUAL & PROCEDURAL BACKGROUND

This matter is before the court on an appeal by taxpayers in a suit involving claims for income tax adjustments and refunds. The facts are not in dispute, and we set them forth as found by the district court. Appellant David A. Koss, a member of the Pennsylvania bar since 1957, agreed with a client in 1971 to perform legal services in exchange for stock in Video...

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