OPINION
GUIN, District Judge.
This is an action for the refund of federal income taxes and penalties paid by the plaintiff with respect to the calendar years 1968 and 1969, plus interest thereon. Plaintiff Bettye A. Sanders ("Bettye") was during these years the wife of Charles J. Sanders ("Charles"), who died on November 2, 1970. Bettye and Charles signed joint federal income tax returns for the years 1968 and 1969. For 1968, Charles reported gross income...
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