MEMORANDUM OF DECISION
KUNZEL, Chief Judge.
In these consolidated actions plaintiffs seek a refund of taxes paid to the United States. The court has jurisdiction by virtue of 28 U.S.C. § 1346(a) (1).
The cases have been submitted for decision on the stipulated facts contained in the pre-trial conference order filed May 1, 1967. Counsel for both parties agree that this is a case of first impression.
Plaintiffs Miles and Allen Yourman...
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