OPINION
SHEEHY, Chief Judge.
This suit involves a claim for refund of certain deficiencies assessed by the Internal Revenue Service against the Plaintiffs in connection with their reported income tax in the year 1958. The material facts established by the stipulations and as found from the testimony and documents introduced at the trial of this cause are as follows.
Alton and Virginia Coats are husband and wife and reside in Gladewater, Texas.
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