CUMMINGS, Circuit Judge.
In this action the government seeks to recover income taxes and interest that it had refunded to defendant members of the Kjellstrom family. Defendants are shareholders or spouses of shareholders in Wisco Industries, Inc., a corporation which elected to be taxed under the provisions of subchapter S of the Internal Revenue Code of 1986 (26 U.S.C. §§ 1361-1379). Under those provisions, a corporation's income or loss (as well as deductions...
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