Court of Appeals for the Ninth Circuit June 17, 1961, 17076 (United States v. W. A. Rushlight, Raymond G. Rushlight, and W. A. Rushlight, of the Estate of Betty Rushlight, Deceased)

JERTBERG, Circuit Judge.

This appeal involves refunds of federal income taxes for the taxable years 1946 through 1950. Jurisdiction was conferred on the district court by Title 28 U.S.C.A. § 1346(a). This Court has jurisdiction under Title 28 U.S.C.A. §§ 1291 and 1294.

In this opinion we will refer to the appellant as the “government” and to the appellees as the “taxpayers”.