YANKWICH, Chief Judge.
Robert L. Farrow and Tonia F. Farrow, husband and wife, in one action seek to recover the total sum of $734.14 which it is alleged was erroneously and illegally collected by the defendant from them as a penalty under § 294(d) (2), Internal Revenue Code of 1939, 26 U.S. C.A. § 294(d) (2), for alleged substantial underestimation of estimated taxes, as follows:
(1) For the tax year 1951, for the sum of $71.06, together with interest...
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