HEEBE, District Judge:
This is a civil action for the refund of federal income taxes and assessed interest in the amount of $25,815.93, which amount the taxpayers contend was erroneously and illegally assessed and collected by the defendant for the years 1959, 1960 and 1961. The taxpayer owns directly 100,220 shares of the stock of Canal Assets, Inc.; he also owned 10,000 shares of stock indirectly through a partnership interest. The taxpayer seeks a refund on the...
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