No. 08-20708.

600 F.3d 362 (2010)

John C. DUFFIE; Melissa Duffie, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

March 10, 2010.

Attorney(s) appearing for the Case

Thomas E. Redding (argued), Sallie W. Gladney, Teresa Jean Womack, Redding & Associates, P.C., Houston, TX, for Plaintiffs-Appellants.

Arthur Thomas Catterall (argued), Michael J. Haungs, Dept. of Justice, Tax Div. Appellate Section, Washington, DC, Michael D. Powell, Dept. of Justice, Tax Div., Dallas, TX, for Defendant-Appellant.

Before KING, JOLLY and STEWART, Circuit Judges.

CARL E. STEWART, Circuit Judge:

John and Melissa Duffie appeal the district court's grant of summary judgment in their tax refund suit. We affirm.

A district court's grant of summary judgment is reviewed de novo, applying the same standard as the district court. Kornman & Assocs. v. United States, 527 F.3d 443, 450 (5th Cir.2008). This court reviews findings of fact for clear error and legal issues de novo. Houston...

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