FLAUM, Circuit Judge.
Abel and Mary Lou Kaplan had no idea that they owed certain overdue taxes to the Internal Revenue Service (I.R.S.). Abel Kaplan held less than a one-percent interest in the profits of a Utah limited partnership that claimed over nine million dollars of invalid deductions for the 1983 tax year. The Kaplans claimed a distributive share of these deductions on their joint income tax return for 1983. The I.R.S. audited the partnership and disallowed...
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