KANNE, Circuit Judge.
Andrew and Joanne Pipitone filed suit for a refund from a federal income tax payment in the amount of $32,511 for the 1995 taxable year. This amount was paid as part of a $95,000 payment Andrew Pipitone ("Pipitone") received from his employer, CNA Insurance Companies ("CNA"), at the time of the termination of his employment. The district court granted the government's motion for summary judgment, concluding that Pipitone failed to introduce any...
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