SIMPSON, Circuit Judge:
The instant appeal is from a judgment entered in favor of the United States as defendant in a suit for recovery of occupational and excise taxes on wagering and of interest and delinquency penalties, which were paid under protest by appellants Albert L. Mersel and Mike Mersel, trading as Mike's News & Sundries (hereinafter "taxpayers"). The trial was to the court, which entered findings of fact and conclusions of law.
Four grounds...
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