OPINION
FIELD, Chief Judge.
In this action the Executors of the Estate of George L. Coyle, Sr., seek to recover income taxes and deficiency interest in the total amount of $8,123.02 assessed and paid in his lifetime by George L. Coyle, Sr., (hereafter called "Taxpayer") for the taxable year 1958. By agreement the case has been submitted on the pleadings, stipulation of facts and briefs.
In 1958 Taxpayer sold 66 shares of the common capital stock...
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