HARRIS, District Judge.
Plaintiffs, husband and wife, have brought an action to recover income taxes in the amount of $2,561.94 allegedly collected in excess of the amounts properly due for the years 1951 through 1953. The amount of refund which plaintiffs seeks is based upon "royalties" paid to L. W. Lasell, husband, for the sale of customer lists and goodwill in 1948 to the Alhambra-National Water Company in connection with the sale of a segment of plaintiffs' business...
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