MEMORANDUM OF OPINION
POINTER, District Judge.
These actions, consolidated for trial, have been brought under 28 U.S.C. § 1346(a) (1) for the refund of income taxes collected on the 1960 incomes of Ellen Gregg Ingalls (CA 66-684) and of the Estate of Robert I. Ingalls Sr., deceased (CA 68-389).
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