MEMORANDUM OPINION AND ORDER
CROWLEY, District Judge.
This is an action for the recovery of personal income taxes assessed and collected pursuant to the Internal Revenue Code of 1954. This Court has jurisdiction under 28 U.S.C. § 1346.
Mary Masterson filed a 1976 joint tax return on behalf of herself and her husband, Bernard, who died on May 29, 1976. She included the amount of a lump sum distribution her husband received from his employer,...
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