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SELLARS v. U.S.

Civil Action Nos. 94-CV-40333-FL, 94-CV-40506-FL.

938 F.Supp. 432 (1996)

Gordon SELLARS, Plaintiff, v. UNITED STATES of America, Defendant and Counterclaim Plaintiff. John Jacob SOLWAY, a/k/a Jack Solway, Plaintiff, v. UNITED STATES of America, Defendant and Counterclaim Plaintiff.

United States District Court, E.D. Michigan, Southern Division.

September 5, 1996.

Attorney(s) appearing for the Case

John S. Regan, Fitzgerald & Dakmak, Detroit, MI, for plaintiffs.

Christine A. Grant, Stephen T. Lyons, U.S. Department of Justice, Trial Attorney, Tax Division, Washington, DC, Nancy A. Abraham, Assistant U.S. Attorney, Flint, MI, for defendants.

MEMORANDUM OPINION AND ORDER

NEWBLATT, Senior District Judge.

The decision in this case depends on the interpretation placed on opinions upon which both parties rely. Huizinga v. United States, 68 F.3d 139 (6th Cir.1995).1

Because plaintiffs rely on a broad interpretation or broad meaning of the principal opinion and its generalized application to the issue in this case...

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