MEMORANDUM OPINION
ROY, District Judge.
This is an action for a refund of $5,690.00, plus interest, costs and attorneys' fees, for federal income taxes assessed against the plaintiffs, husband and wife, for the tax years 1979 and 1980. The disagreement between the taxpayer (since the returns were joint the wife is a named party but reference hereafter will be only to the husband) and the government was caused by the disallowance of business deductions claimed...
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