WINTER, District Judge:
Mr. and Mrs. Pannill Martin (taxpayers) sue to recover income taxes and interest assessed, in the total amount of $298,959.68, for the calendar years 1959 and 1960. During those years taxpayers, individually and not jointly, were the majority stockholders of The Cloverdale Spring Company (Cloverdale), a soft drink bottling company. The assessments were made by charging to taxpayers' income a proportionate share of the payment of $3,000.00 by...
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