SULLIVAN, District Judge.
This complaint seeks the recovery of income taxes paid for the year 1944. The relevant facts have been stipulated, and both parties seek summary judgment. The cause is a consolidated one involving two taxpayers, husband and wife, whose income for the years in question was derived from a business in which they were partners. From this partnership, each had taxable income for the years 1944 and 1945, and a net operating loss for 1946. Within...
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