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KAPPUS v. C.I.R.

No. 02-1145.

337 F.3d 1053 (2003)

Tom KAPPUS and Louise Kappus, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided August 8, 2003.

Attorney(s) appearing for the Case

Lawrence P. Postol argued the cause and filed the briefs for appellants.

Frank P. Cihlar, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Robert J. Branman, Attorney. John A. Nolet, Attorney, entered an appearance.

Before: GINSBURG, Chief Judge, and EDWARDS and GARLAND, Circuit Judges.

Opinion for the court filed by Circuit Judge GARLAND.

GARLAND, Circuit Judge:

Tom and Louise Kappus, United States citizens living in Canada, appeal from a decision of the United States Tax Court denying their challenge to a notice of deficiency in their federal income tax issued by the Commissioner of Internal Revenue. The Kappuses claimed a credit against their U.S. tax for all of the taxes they paid to Canada on their Canadian-source income, leaving them...

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