OPINION AND ORDER
REYNOLDS, District Judge.
This action is a suit for refund of additional assessments on plaintiffs' joint income tax returns for 1963 and 1964. This court has jurisdiction of such a suit pursuant to 28 U.S.C. § 1346. The matter was tried to this court, sitting without a jury, and post-trial briefs have been submitted by counsel. The court is now prepared to make its findings of fact and conclusions of law pursuant to Rule 52 of the...
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