CECIL, Senior Circuit Judge.
The plaintiffs-appellants, John L. Greer, Sr., and his wife, Russell Z. Greer, brought this action in the District Court against the United States for a refund of income taxes, in excess of $37,000, alleged to have been illegally assessed and collected. Mrs. Greer is a party only because she signed joint income tax returns with her husband for the tax years in question. For this reason we will refer to Mr. Greer alone as the taxpayer....
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