MEMORANDUM DECISION
NICHOL, Chief Judge.
This action to recover a total of $259,184.00 in taxes and deficiency interest, plus statutory interest, was tried to the court upon stipulated facts.
Plaintiffs, Marvin H. Teget and his wife, are joint taxpayers residing in Yankton, South Dakota, where Marvin has been employed since 1960 by Nicolson, Inc.
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