PER CURIAM:
In these consolidated appeals, taxpayers assert error in the judgment rendered by the District Court on June 25, 1974, in favor of the government, in a refund suit against the government for taxes allegedly overpaid. The facts are not in dispute.
The district court stated, "The issue is whether, in computing earnings and profits, plaintiffs can take advantage of the Section 1248(d)(2) exclusions without taking into account the recapture of depreciation...
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