LEVET, District Judge.
This is a motion for summary judgment by defendant, pursuant to Rule 56 of the Federal Rules of Civil Procedure.
Plaintiffs are the trustees of a residuary trust. On January 25, 1960, the plaintiffs paid a deficiency income tax for the calendar year 1954 in the amount of $6,612.40. On March 9, 1960, interest of $1,896.49 was paid on the deficiency. The deficiency asserted against the plaintiffs for the year 1954 was based on a determination...
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