ARNOLD, Circuit Judge.
This is an action for refund of individual federal income taxes. The plaintiff, Dr. Donald D. Corbin, was employed by the Fox C-Six School District of Jefferson County, Missouri, an educational organization described in § 170(b)(1)(A)(ii) of the Internal Revenue Code. On May 18, 1982, the employer adopted a plan under which employees could agree to have their salary reduced, with the amount thus saved being contributed to a nontransferable...
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