MEMORANDUM AND ORDER
STUART, District Judge.
Taxpayers brought this action to recover refunds they maintain are due because of wrongful assessments of additional income tax, interest and penalties for the years 1963, 1964 and 1965.
Taxpayers are husband and wife who reside in Des Moines. They have substantial holdings in bonds, stocks and real estate. During the years in controversy here, they also had significant amounts of tax-exempt bonds which...
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