MEMORANDUM AND ORDER
BRATCHER, District Judge.
This is an action against the United States for the refund of income taxes paid by plaintiff in the sum of $11,780.89 for the years 1968, 1969 and 1970. The case has been submitted to the Court on an agreed stipulation of facts, interrogatories and briefs. Jurisdiction is based on 28 U.S.C. § 1346(a)(1).
The pertinent stipulated facts as set out by the parties are as follows:
1. The Evergreen...
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