DECISION OF THE COURT
THEIS, District Judge.
The above actions were consolidated for trial and arose under the Internal Revenue Code of 1954, 26 U.S.C.A. § 1, et seq. The cause was submitted to the Court upon stipulated facts, briefs of the parties, and without formal hearing. On the basis of those facts, and after a careful reading of the briefs of the parties and the applicable law, the Court finds as follows.
As a preliminary matter, it is...
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