OPINION AND ORDER
GOURLEY, Senior District Judge.
This is a federal income tax proceeding presented to the Court through an interpleader action. The Court has conducted a full and complete hearing, afforded all parties the opportunity to be heard, and it has been agreed that adjudication shall be entered on the basis of a case stated. The taxpayer was involved in an automobile accident, secured legal counsel, instituted a lawsuit against the tortfeasor,...
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