DONOVAN, District Judge.
This action was commenced to recover a refund of taxes paid by the plaintiffs to the Commissioner of Internal Revenue and is based upon Section 107 of the Internal Revenue Code of 1954, hereinafter referred to as Section 107.
The material facts have been stipulated. The plaintiffs, David E. Ling and Jo Ann Ling, were and are husband and wife during the entire period of the instant case and are presently...
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