BARNES, Circuit Judge.
This case arises upon a claim for refund of taxes paid. The district court had jurisdiction under 28 U.S.C. § 1346, while this court's jurisdiction over the appeal rests upon 28 U.S.C. §§ 1291 and 1294. Although this case involves both Paul and Wineta Dorman, as husband and wife, the controlling facts involve only Paul Dorman; thus references below will be in the singular to Dorman or "appellant."
In January 1952 appellant...
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