MEMORANDUM OPINION
HARPER, District Judge.
This matter is before the Court on the cross motions of plaintiffs and defendant for summary judgment.
Plaintiffs, Theodore Krupin and Barbara Krupin, his wife, brought this action to recover a refund of federal income tax and interest which was paid by them in full satisfaction of an assessment made against plaintiffs for the tax year 1973. Dr. Barbara Krupin is a plaintiff in this suit only because she...
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