OPINION
COLLINS, Judge.
This is an income tax refund action by plaintiff to recover the sum total of $12,558.08, which was illegally collected from plaintiff by defendant for the taxable years 1962 and 1963, plus statutory interest from date of payment. The case is before this court on the agreed upon stipulation of facts. Since the facts have been stipulated, they will be summarized here only to the extent necessary to explain the basis of the court's decision...
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