PER CURIAM:
The appellant and his wife brought an action against the United States to recover an alleged overpayment of income tax. The United States counterclaimed for the recovery of additional taxes. The district court entered judgment for the United States. The factual situation which gave rise to the controversy and the conclusions of the district court in reaching its decision are set forth in its opinion. Goodling v. United States, S.D.Miss., 1966,
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