MEMORANDUM OPINION
BUNTON, District Judge.
This is an action brought by Plaintiff-taxpayers WILLIAM C. and LAURINE L. DOSHER to recover taxes paid by them in satisfaction of a deficiency in income taxes assessed for the tax year 1976. The parties have agreed that there are no contested issues of fact, and the Court is therefore entering this opinion on the basis of the briefs submitted by each party. After reviewing said briefs, the relevant authorities...
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