ON PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT AND DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT
BENNETT, Judge.
This contract case, before the court on the parties' cross-motions for summary judgment, arose out of a tax dispute litigated in the Tax Court in the mid-1960's, over alleged tax deficiencies said to be owing from the early 1940's. After obtaining an adverse decision from the Tax Court in 1964, Jackson v. Commissioner,
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