MEMORANDUM OPINION
MOYNAHAN, Chief Judge.
The plaintiff herein, together with his wife, Charline Combs, filed for the calendar year 1969 a joint federal income tax return. The Commissioner of Internal Revenue, by a statutory notice of deficiency dated April 10, 1973, assessed a deficiency against the taxpayers in federal income taxes in the amount of $65,706.20 for the tax year 1969. The plaintiff subsequently paid this additional amount of tax in June,...
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