MEMORANDUM OPINION and ORDER
ROBERTS, District Judge.
This cause was heard by the Court, sitting without a jury, in Austin, Texas, on April 12, 1976, and after carefully considering the evidence the Court enters this Memorandum Opinion and Order, which shall constitute findings of fact and conclusions of law. This is an action for the refund of $15,161.40 of income tax and interest paid by plaintiffs, Joe R. Long and Teresa
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