MEMORANDUM
LARSON, District Judge.
Plaintiffs are the trustees in the voluntary dissolution of the Naegele Advertising Companies, Inc. (hereinafter Naegele). On behalf of the stockholders of that corporation they allege that the Government assessed and collected taxes substantially in excess of that amount which Naegele owed for the year 1963. This Court's jurisdiction lies under 28 U.S.C. § 1346(a)(1).
The parties have stipulated to the facts...
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