MOORE, Circuit Judge.
In this tax refund case, plaintiffs lay claim to net operating loss deductions purportedly left over from their liquidated bankruptcy estate. The district court granted summary judgment for the United States on two grounds: (1) the refund claims for tax years 1986 and 1987 were time barred; (2) no net operating losses remained for the plaintiffs after such losses were reduced by the amount of debt discharged in the estate's bankruptcy proceeding...
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