District Court, D. Colorado March 23, 1982, Civ. A. 81-K-1951 (Ardalan v. United States)

MEMORANDUM OPINION AND ORDER

KANE, District Judge.

This is a tax refund suit against the United States under 28 U.S.C. § 1346(a)(1).

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Plaintiffs allege that throughout 1977 they were citizens and residents of Iran. They further allege that during 1977 neither of them had any income derived from within the United States.