SUHRHEINRICH, J., delivered the opinion of the court, in which MOORE, J., joined. McKINLEY, D.J. (p. 726), delivered a separate dissenting opinion.
SUHRHEINRICH, Circuit Judge.
Defendant United States appeals and plaintiff taxpayers cross-appeal from the district court's partial grant and partial denial of plaintiffs' and defendant's cross motions for summary judgment on plaintiffs' claims for refund of income taxes. The parties disputed the amount of allowable...
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