Court of Appeals for the Fourth Circuit December 10, 1990, 89-1756 (Arthur C. Ewing A/K/A A. Clifford Ewing Maxine H. Ewing v. United States)

SPROUSE, Circuit Judge:

The underlying action was initiated in the district court by Arthur C. Ewing and Max

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ine H. Ewing (taxpayers) for return of sums they had remitted to the Internal Revenue Service after tax audits resulted in an agreement by the taxpayers and the government concerning deficiencies for previous tax years.