MEMORANDUM OPINION
ROBERT M. HILL, District Judge.
George T. Kimbell and Ruth A. Kimbell, plaintiffs, have brought this suit against the United States of America pursuant to 28 U.S.C. § 1346(a). Plaintiffs, who are husband and wife, seek a refund of income taxes alleged to have been improperly assessed and collected for their taxable year 1967. The sole issue presented by this suit is whether a payment in settlement of a threatened lawsuit is deductible...
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