MEMORANDUM OPINION
This suit involves a claim by plaintiff taxpayers for a refund of federal income taxes. Dr. Tobin seeks a refund of $562.12, paid for the year 1966, and Dr. Reeves submits a claim for $873.93, paid for the years 1966 and 1967. During the period in controversy, both taxpayers were resident physicians in otolaryngology participating in the Affiliated Hospitals Residency Program of the Baylor University College of Medicine. As a result of such participation...
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