HARRIS, District Judge.
Plaintiffs, husband and wife, seek to recover $6,886.55, plus interest, from defendant. The amount, which is not disputed, represents a penalty assessed and collected from plaintiffs under Section 294(d) (2) of the Internal Revenue Code the following:
Included in the stipulated facts are of 1939, 26 U.S.C.A. § 294(d) (2).
The taxpayers did not file their declaration of estimated tax for the year 1951, which was required...
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