MEMORANDUM OPINION
BREWSTER, Chief Judge.
The taxpayer originally instituted this suit against the District Director of Internal Revenue seeking to enjoin him from collecting income tax liabilities for the years 1969 and 1970, allegedly due and owing by taxpayer, and seeking a refund of $354.00, plus interest, for taxes allegedly paid by taxpayer to the Internal Revenue Service.
A pre-trial hearing has been held and a pre-trial order was entered...
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