MEMORANDUM
WANGELIN, District Judge.
This action arises under the Internal Revenue Laws of the United States and is for refund of individual income taxes alleged to have been erroneously assessed and collected. The parties have submitted to the Court a Stipulation of Fact and Issue of Law which is hereby adopted as this Court's findings of fact.
Edwin W. and Maxine G. Hudspeth, plaintiffs herein, timely filed their joint individual income tax return...
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