DECISION AND ORDER
MYRON L. GORDON, Senior District Judge.
These two cases were jointly tried to the court on May 12, 1983. This opinion constitutes my findings of fact and conclusions of law pursuant to Rule 52(a), Federal Rules of Civil Procedure.
In both cases the plaintiff seeks a refund of taxes which he contends were wrongfully collected from him by the Internal Revenue Service. He asserts that this court has jurisdiction under 28 U.S.C. &...
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