CLARIE, District Judge.
The plaintiffs prepared and filed their income tax returns for the calendar year 1958 and availed themselves of the deductions allowed to the stockholders of a "small business corporation", in accordance with the provisions of Subchapter "S", §§ 1371-1377 of the Internal Revenue Code of 1954, as amended by the Technical Amendments Act of 1958, 26 U.S.C.A. §§ 1371-1377. It is their claim that The Joseph Simons Company made...
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