Opinion by Judge Beezer.
BEEZER, Circuit Judge:
Duane H. Wall filed an action seeking a refund of federal income taxes and interest for taxable year 1982 arising out of his participation in a limited partnership. The district court denied Wall's motion for summary judgment and entered a stipulated judgment in favor of the United States. We have jurisdiction over this timely appeal, see 28 U.S.C. § 1291, and we affirm.
I
Wall participated...
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