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SINGLETON v. U.S.

No. 5:95-CV-15-BR2.

935 F.Supp. 703 (1996)

Carroll Eugene SINGLETON and Sheila Singleton, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. North Carolina, Western Division.

May 8, 1996.

Attorney(s) appearing for the Case

Charles Nichols, Manning, Fulton & Skinner, Raleigh, NC, for plaintiffs.

Lawrence P. Blaskopf, U.S. Department of Justice, Trial Attorney, Tax Division, Washington, DC, for defendant.

ORDER

BRITT, District Judge.

Before the court are the parties' cross-motions for summary judgment. A hearing was held before the undersigned on 21 March 1996. The issues have been fully briefed and addressed, and this matter is thus ripe for disposition.

I. FACTS

In August 1988, plaintiffs filed their income tax return for the tax year 1987. On such return, plaintiffs claimed the...

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