MEMORANDUM OPINION
GUIN, District Judge.
Central Bank of the South and Eleanor A. Russell, executors of the estate of E. Lonnie Russell, deceased, and Eleanor A. Russell, individually, bring this action under 28 U.S.C. § 1346 against the United States of America for the recovery of income tax and interest thereon which was assessed against and paid by E. Lonnie Russell and Eleanor A. Russell for the years 1978 and 1979. This cause was heard before the...
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