Court of Appeals for the Eleventh Circuit March 19, 1984, 82-8738 (United States v. D.N. Stafford and Flora C. Stafford)

R. LANIER ANDERSON, III, Circuit Judge:

Taxpayers DeNean and Flora Stafford appeal the district court’s summary judgment in favor of the government on their refund action for allegedly overpaid taxes. The refund action involves the Staffords’ 1969 tax return, in which they did not account for their receipt of a limited partnership interest valued at $100,000.