MEMORANDUM OF DECISION
KUNZEL, Chief Judge.
This is an action for the recovery of federal income taxes assessed against and collected from plaintiff for the taxable years ended December 31, 1962, 1963, and 1964.
Federal jurisdiction is invoked by virtue of 26 U.S.C.A. (I.R.C.1954) § 7422, 28 U.S.C.A. § 1346(a) (1) and § 1402 (a) (1) and the Internal Revenue Laws of the United States. Cross motions for summary judgment have been filed...
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