MEMORANDUM OPINION AND ORDER
KEELEY, District Judge.
The parties to this case have filed cross-motions for summary judgment. Plaintiffs, Francis L. Miller, Jr. and Ruby F. Miller (sometimes "the Millers"), contend that they are entitled as a matter of law to recover federal income tax and interest erroneously assessed and collected for the tax year ended December 31, 1993. They argue that the passive activity loss and nonrecourse liability rules embodied...
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