DAVIS, Judge.
Mr. and Mrs. Gooding have brought these refund suits to regain admitted overpayments of income taxes for 1946. Under the stipulated facts, recovery is time-barred unless the mitigation portion of the Internal Revenue Code of 1954, §§ 1311-1315, or the doctrine of equitable recoupment is applicable.
On August 24, 1946, the Goodings and their minor daughter, who had operated an amusement-park equipment business as partners, transferred...
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