MEMORANDUM OPINION
HARPER, Chief Judge.
This is a suit for income tax refund, with jurisdiction founded upon 28 U.S. C.A. § 1346(a) (1). Originally instituted by Dan and Mary Rosenberg, pursuant to Rule 25 upon the untimely death of the taxpayer Dan Rosenberg, the present parties were substituted and this action shall proceed in their favor. In view of the fact that the suit deals solely with the income and earnings of Dan Rosenberg for the tax years...
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