MEMORANDUM OPINION
WOLLENBERG, District Judge.
This is an action for the recovery of Federal income taxes paid under protest by the plaintiffs Richard J. Nasser (hereinafter, "taxpayer") and his wife for the years 1960 and 1961. This court's jurisdiction derives from 28 U.S.C. § 1346(a) et seq. This opinion embodies the Court's findings of fact and conclusions of law as required by F.R.Civ.P. 52(a).
Plaintiffs are husband and wife and reside...
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