BOWMAN, Circuit Judge.
James P. and Freda Alford appeal from the decision of the District Court granting summary judgment in favor of the United States on the Alfords' claim to recover income tax and interest paid to the Internal Revenue Service (IRS). We reverse and remand.
The Alfords, husband and wife, timely filed joint federal income tax returns for the tax years 1986, 1987, and 1988. The IRS assessed deficiencies against the taxpayers for those three...
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