PER CURIAM.
On the grounds and for the reasons stated in its opinion, Shearer v. Smyth, D.C.N.D.Cal., 116 F.Supp..230, the judgment of the District Court is affirmed.
Joseph E. SHEARER and Georgia P. Shearer, Appellants, v. James G. SMYTH, United States Collector of Internal Revenue, Appellee
221 F.2d 478
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