Memorandum Opinion
HENLEY, Chief Judge.
This is a suit for refunds of federal income taxes brought by Drs. Deane D. Wallace, Alex T. Gillespie, and James O. Porter of Little Rock, Arkansas, who are stockholders in and employees of a professional service corporation known as the Wallace, Gillespie & Porter Professional Association, hereinafter called the "Association," organized in 1962 under the provisions of the Arkansas Medical Corporation Act.
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