SOBELOFF, Circuit Judge.
This is an appeal from a determination by the District Court, sitting without a jury, that the taxpayers were liable for unpaid federal cabaret taxes plus penalties and interest, for the years 1950 through 1959, in the amount of $121,460.14.
In April, 1963 the District Director, acting in behalf of the Commissioner of Internal Revenue, mailed to the taxpayers a "Statement of Tax Due," in the total amount of $255,821.09 for excise tax...
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