JOHNSON, District Judge.
This is an action by the receivers of the Temple Coal Company against the collector of internal revenue seeking the recovery of taxes for the years 1921 and 1923 alleged to have been erroneously retained by the collector in satisfaction of the tax liability of the Lackawanna Coal Company for said years.
On March 14, 1922, and March 15, 1924, the Temple Coal Company filed consolidated income tax returns on forms 1120 on behalf of itself...
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