MEMORANDUM OPINION
KEADY, Chief Judge.
In this action, plaintiffs John and Imogene Stanley seek refund of alleged overpayment of their federal income tax for the calendar years 1971 and 1972. The cause is before the court on cross-motions for summary judgment.
Plaintiffs' claim is based on the contention that in the above years they were entitled to taxation of liquidating dividends attributable to certain shares of stock of King & Stanley Company...
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