ORDER and JUDGMENT
BRIMMER, District Judge.
After a trial to the bench (with an advisory jury), the Court makes the following findings of fact and conclusions of law.
Findings of Fact
The Maloneks timely filed a joint federal income tax return for tax year 1984. In this return, the Maloneks calculated that they owed $12,920.85 in taxes to the United States. The IRS assessed and the Maloneks paid these taxes.
On April...
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