MEMORANDUM OPINION
DAUGHERTY, District Judge.
This action for refund of fraud penalties assessed and paid was brought by the widow of Roy J. Melinder, M. D. in her individual capacity and as Executrix of the Estate of Dr. Melinder. The Plaintiffs will hereinafter be referred to as "Taxpayer" and the Defendant as "Government." The Taxpayer objected to certain evidence offered at trial, and these objections will be disposed of before proceeding to the merits...
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