SOPER, Circuit Judge.
These actions were brought by R. C. Shelton, Jr. and Duckworth & Shelton, Inc., respectively to enjoin the collection of income taxes, penalties and interest in the sum of $70,191.06 covered by a jeopardy assessment issued on August 5, 1952 against the complainants as transferees of Raymond B. Duckworth and Dorothy L. Duckworth, his wife, by whom the tax liability to the United States in the sum mentioned had been incurred. In each case the...
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