OPINION
GOODWIN, District Judge:
Taxpayers bring this action under 28 U.S.C. § 1346(a) (1) for a refund of income taxes paid after the Internal Revenue Service disallowed ordinary-income deductions for business bad debts and worthless stock.
James and Helen Rookard filed a joint return for 1967. They claimed business bad-debt deductions totaling $25,618.58 under 26 U.S.C. § 166. This sum included $20,618.58 which James Rookard was required...
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