MEMORANDUM OF DECISION
ARTHUR J. STANLEY, Jr., Senior District Judge.
This is an action to recover taxes which the plaintiffs allege to have been illegally and erroneously assessed and collected. The parties, as a part of the pretrial order, have stipulated as to the facts and have submitted the case to the court for determination.
The facts material to a resolution of the case are as follows: The plaintiffs are husband and wife, who have resided...
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