MATTHES, Circuit Judge.
In these actions separately instituted and later consolidated, appellees seek refunds of Federal income taxes paid for the years 1961 and 1962. Taxpayers in each case are husband and wife, having filed joint Federal income tax returns for the years in question. All parties agreed that the only issue for determination was whether each pair of taxpayers was entitled to deduct on their 1961 and 1962 joint returns, as ordinary and necessary nonbusiness...
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