OPINION AND MEMORANDUM OF DECISION AND JUDGMENT
SCHWARTZ, District Judge.
This is an action brought by an individual and a corporation for refund of federal income taxes paid for the year 1959. Clyde Hufbauer as an individual, and Clyde Hufbauer, Architect, Inc., a California corporation, each seeks to recover on the theory of equitable recoupment taxes paid in the amount of $32,521.98 for income earned during...
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